Diversifying ownership will become an increasingly important strategy in light of the new restrictions to APR and BPR, writes Michael Thomas KC (Pump Court Tax Chambers).
So the Halloween Budget has taken a scythe to the key IHT reliefs for both business and agricultural property ‘BPR’ and ‘APR’ respectively. Longstanding fears that these reliefs were to be curtailed have been realised and the changes will take effect from 6 April 2026 with some anti-forestalling rules.
The new rules are summarised in last week’s edition of this journal(‘Autumn Budget 2024 report’ Tax Journal 1 November 2024). In summary each taxpayer will have a £1m combined allowance for both BPR and APR. This will cover assets which qualify for 100% relief up to that value. The allowance covers both lifetime transfers and transfers on death (including failed potentially exempt transfers (PETs)). Assets above that...
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Diversifying ownership will become an increasingly important strategy in light of the new restrictions to APR and BPR, writes Michael Thomas KC (Pump Court Tax Chambers).
So the Halloween Budget has taken a scythe to the key IHT reliefs for both business and agricultural property ‘BPR’ and ‘APR’ respectively. Longstanding fears that these reliefs were to be curtailed have been realised and the changes will take effect from 6 April 2026 with some anti-forestalling rules.
The new rules are summarised in last week’s edition of this journal(‘Autumn Budget 2024 report’ Tax Journal 1 November 2024). In summary each taxpayer will have a £1m combined allowance for both BPR and APR. This will cover assets which qualify for 100% relief up to that value. The allowance covers both lifetime transfers and transfers on death (including failed potentially exempt transfers (PETs)). Assets above that...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
