MP Estate Planning UK

Inheritance Tax Planning for Farmers: Protect the Family Land

inheritance tax planning for farmers uk

We explain, in plain language, what the April 2026 changes mean for land-owning families.

Since 1984 reliefs helped keep farms intact across generations. From April 2026, reliefs will change, and a new £1m allowance will alter how much levy applies above that cap.

We set out why this has moved from a future task to a “do it this year” priority. Our aim is simple: protect the land and the business so the next generation can carry on without forced sales or splits.

This short guide is a buyer’s map. It helps you turn up to meetings with solicitors and advisers with clear questions, the right paperwork and a practical brief.

We cover who this affects — owner-occupiers, tenant operators, family partnerships and mixed estates — and what you’ll learn about allowances, wills, lifetime gifting and insurance as a funding option.

For local support and detailed advice see our guide on inheritance tax planning for farmers uk.

Key Takeaways

  • April 2026 reduces reliefs and adds a £1m per-person allowance.
  • Acting this year can reduce the chance of a forced sale or split.
  • Our guide helps you prepare for solicitor and adviser meetings.
  • The core goal is keeping the farm and land within the family and for the next generation.
  • Every estate is different — professional advice is essential.

Why April 2026 changes make farm inheritance tax planning urgent

April 2026 brings changes that make prompt action essential for many rural estates.

What APR and BPR aimed to protect

When agricultural property relief and business property relief began, the idea was simple. They stopped working farms being carved up to meet a bill and encouraged land to stay in productive use.

april 2026 land relief

What changes from April 2026 and why liability rises

From April 2026, only the first £1m per person of qualifying APR/BPR keeps 100% relief. Amounts above that get 50% relief. That means a 40% levy on the full value turns into an effective 20% charge on the excess.

Put simply: if a parcel of land or buildings sits above the cap, the cash call at death can become real rather than theoretical.

Which assets could be affected

Typical assets to review include land, the farmhouse and other property, farm buildings, machinery and livestock. Valuation and ownership structure decide eligibility and the resulting liability.

  • Land and farmhouses often hold most value and risk.
  • Machinery and equipment may or may not qualify depending on use.
  • How assets sit between spouses or partners alters the outcome.

We walk clients through these practical points and link to more detail on agricultural property relief and woodland relief. Acting now gives you options that shrink as values move closer to the April 2026 change date.

Inheritance tax planning for farmers uk: how the new £1m APR/BPR allowance works

A new £1m cap reshapes how agricultural and business reliefs protect land at death. We explain the mechanics so you can see the cash effect and practical choices.

The £1m per person allowance and the 50% relief above the cap

The first £1m of qualifying agricultural property or business property keeps 100% relief. Value above £1m gets only 50% relief, which creates a real tax charge on the excess.

Why the allowance is lost if unused and cannot pass to a spouse

This allowance does not transfer. If the first to die does not use their £1m, it is lost. Spouse transfers remain exempt, but they can waste the first-death allowance.

How couples can use two allowances and when spouse exemption may cost more

Careful wills can let couples use both allowances so up to £2m passes free of charge to the next generation. But simply shifting everything to a spouse can be less efficient for long-term succession.

  • Repeatable kitchen-table phrase: first slice 100% relieved; next slice 50% relieved.
  • Estimate the potential tax hit and include cash-flow in estate planning decisions.
ScenarioValueRelief
Single estate under £1m£900,000100% relieved
Single estate £1.5m£1,500,000£1m relieved; £500,000 at 50% relief
Couple using wills£2m£2m relieved if structured correctly

inheritance tax planning for farmers uk

Buyer’s guide to will and succession planning strategies for farming families

Many landowning families face a fresh dilemma: wills drafted under old rules may not do what you expect.

Start with a quick check. If your will dates from before October 2024, it may assume full APR/BPR relief. That assumption can create an avoidable charge on death.

Locking an allowance with targeted legacies

Leaving a named legacy to children or grandchildren can use a partner’s £1m allowance on first death. This keeps value within the family while preserving income for the survivor when needed.

Rebalancing ownership between spouses

Moving qualifying assets now can let each spouse use their own allowance later. Spousal transfers are often CGT-exempt and can be a practical step to reduce future liability.

Aligning wills with business structures

Make sure wills match partnership agreements and company articles. Misalignment can cause delays and disputes. We advise bringing agreements and valuations to any meeting.

When trusts support control and fairness

Trusts can protect the farm where there are young beneficiaries, a second marriage or vulnerable relatives. They help keep control while allowing use and benefit.

“Prepare a clear timeline, set meeting goals and bring titles, accounts and a family tree.”

— NFU-style checklist
  • Set meeting goals and a timeline.
  • Bring wills, partnership deeds and valuations.
  • Discuss fairness between non-farming children and the next generation.
ActionWhy it mattersWhen to do it
Review wills dated before Oct 2024May assume full relief and misallocate allowanceAs soon as possible
Leave targeted legacy to children/grandchildrenUses first-death £1m allowanceWhen wills are updated
Rebalance ownership to spouseAllows use of both allowances laterAfter legal and tax advice
Consider trustsProtects control and manages fairnessWhen beneficiaries are complex

succession planning

For a practical checklist to take to advisers, see our farm succession checklist. Seek professional advice from a solicitor with an agricultural specialism.

Lifetime planning options: gifting the farm, the seven-year rule and transitional timing

Gifting land can remove value from your estate, but it starts a seven-year clock and brings practical trade-offs. We set out the key points so you can judge whether giving now makes sense for your family and the business.

Potentially Exempt Transfers (PETs)

A gift of agricultural property can be a PET. If you survive seven years after the gift, the asset normally falls outside the estate and no charge applies. That makes lifetime moves a clear route to reduce future liability.

Taper relief and death within seven years

If death happens inside the seven-year window, a sliding scale of relief applies. After three years taper relief begins to reduce the charge. The nearer to seven years you get, the lower the eventual bill.

Transitional rules from 30 October 2024

Gifts made on or after 30 October 2024 may still face the new £1m cap if death occurs on or after 6 April 2026 within seven years. That timing can affect how much relief the gift achieves and what liability remains.

Capital Gains considerations

Remember CGT. Gift Hold-Over Relief can defer gains in qualifying cases so a lifetime gift does not trigger an immediate capital charge. Always check whether hold-over relief applies before assuming a net benefit.

Control versus certainty: giving ownership away changes who can sell or borrow against the land. We recommend mapping your situation with valuations and records and discussing outcomes with an adviser.

lifetime gifting land

For practical steps on exempt gifts and how they work in action see our guide on protecting your family’s assets with exempt.

Managing the cash cost: life insurance and funding potential tax bills

Even well-structured transfers can leave a short-term bill that needs a sensible funding solution. Farms often hold value in land, not cash. That can create a real liquidity gap.

Seven-year term cover

life insurance

A seven-year term policy can protect against the charge on gifts while the seven-year clock runs. For example, gifting a £5m farm with £1m exempt leaves £4m potentially chargeable. At an effective 20% that creates an initial liability of about £800,000 if death occurs soon after the gift.

Fixed-term and whole-of-life options

Fixed-term cover suits those who plan gifts soon. Whole-of-life cover helps when giving isn’t practical because parents still rely on the farm income or want to retain the house.

Keeping cover aligned with rising value

Policies can be inflation-linked or stepped to track land value. Regular reviews stop cover becoming too small.

OptionWhen it helpsIndicative cost
7-year termAfter a lifetime giftExample: £800,000 cover — premiums vary (indicative only)
Fixed-term to ageWhen timing is knownMonthly premiums for younger clients may be modest
Whole-of-lifeWhen gifting is not yet possibleHigher long-term cost but guaranteed payout

Buyer’s questions: who should own the policy, how proceeds will be paid, and how cover sits with wills and trusts. We recommend taking these to a specialist adviser. Insurance is a cash cushion — not a replacement for proper estate work.

Conclusion

A clear, practical response now will keep options open for the farm and the next generation.

From April 2026 the relief landscape changes and that makes active review essential. Use both partners’ allowances with carefully drafted wills, consider sensible lifetime gifts and align succession with the business structure.

Doing nothing is still a decision. It can raise the estate levy and reduce choices when the family most needs them.

Simple next steps: check the date on your will, gather valuations and deeds, map asset ownership and book time with an agricultural specialist solicitor and adviser. If you want local guidance, see our short guide to secure your family’s future.

Good planning protects people as much as it saves money. Keep conversations open, document decisions, and get specialist advice tailored to your holding.

FAQ

What are Agricultural Property Relief (APR) and Business Property Relief (BPR)?

APR and BPR are reliefs that reduce the value of qualifying land, buildings or business assets when worked out for estate charges on death. APR typically applies to occupied agricultural land and some farm buildings. BPR covers trading businesses and assets used in a farming business. Both can cut or remove the assessed liability, but the exact relief depends on use, ownership and how actively the farm is run.

Why do the changes from April 2026 make planning urgent?

From April 2026 the rules change the way APR and BPR interact and introduce a new £1m allowance per person with different tapering above that cap. That raises the risk of a larger charge if you delay. Plans that relied on older assumptions — especially wills and ownership structures drafted before October 2024 — may no longer deliver the anticipated protection. Acting now gives time to rework ownership, wills and gifting to lock in better outcomes.

Which farm assets are most at risk under the new rules?

Land, the farmhouse, trading buildings, valuable machinery and livestock can all be affected. Residential property on the holding can be scrutinised for APR eligibility. Non‑trading assets, high-value land sold or let, and assets held partly as investment rather than as part of the farm business are most likely to lose full relief and attract an assessed charge.

How does the new £1m APR/BPR allowance work?

Each individual receives a £1m allowance that applies to qualifying agricultural or business property on death. Above that, only 50% relief applies to the excess value. The cap is applied per person, so married couples or civil partners can potentially access up to £2m between them if structured correctly.

Can an unused £1m allowance be transferred to a spouse or civil partner?

No. The new £1m allowance is personal and cannot be transferred to a surviving spouse or civil partner. That makes early planning between partners important so both can use their allowances while still alive or through appropriate rebalancing of ownership.

How can couples use allowances to reach £2m of protection?

Couples can rebalance asset ownership so qualifying property sits in both names. That may involve transferring a share of land or business assets or changing partnership agreements. Wills and lifetime transfers can also be used to ensure each person’s £1m allowance is available on their death. Professional advice is essential to avoid unintended tax or capital gains consequences.

When is claiming spouse exemption still useful and when can it be less effective?

Spouse exemption can defer a charge because transfers between spouses are generally exempt on death or lifetime. However, simply leaving everything to a surviving partner can mean losing the chance to use the second person’s separate allowance while both are alive. Where succession to the next generation is the aim, direct use of each person’s allowance may be more tax‑efficient than relying solely on spouse exemption.

What risks do wills written before October 2024 present?

Older wills may assume full APR or BPR for certain assets. Under the new rules, those assumptions can be wrong. That creates a risk that beneficiaries face a larger charge or that the planned split between family members no longer works. Reviewing and updating wills ensures they reflect the new allowances and the family’s succession goals.

How can legacies help lock in a partner’s allowance for children or grandchildren?

Leaving a specific legacy to children or grandchildren can fix who benefits from certain assets and allow each partner’s £1m allowance to be used separately. For example, directing a share of qualifying land to children on one partner’s death can preserve the surviving partner’s own allowance for later use. This must be drafted carefully to avoid disputes and unintended tax consequences.

When should ownership be rebalanced between spouses?

Rebalancing is useful when one partner holds most qualifying assets and the couple wants to use both allowances. It is often appropriate before gifts are made or before death to ensure the correct proportions. Timing matters for capital gains and potential loss of business relief, so professional guidance is important before transferring ownership.

How should succession planning align with partnership or company structures?

Succession must reflect how the business is run. Partnership agreements, shareholder arrangements and tenancy agreements can all affect who qualifies for relief. Updating these documents to match the family’s succession plan reduces the risk of relief being denied or assets being tied up in dispute.

When might trusts be useful in farm succession?

Trusts can protect family control, provide for younger generations and manage timing of transfers. They may also help mitigate future charges when used with care. Trusts add complexity and cost, and they can affect reliefs and allowances, so we recommend specialist legal and tax advice before proceeding.

What are Potentially Exempt Transfers (PETs) and the seven‑year rule?

PETs are gifts made in lifetime that become exempt if the donor survives seven years. If death occurs within seven years, taper relief can reduce the charge depending on how many years passed. PETs can be a key tool to reduce the estate’s assessed value, but timing and documentation are crucial.

How does taper relief work if death occurs within seven years?

Taper relief reduces the charge on gifts made between three and seven years before death. The reduction increases with time. Gifts in the first three years get no reduction. Exact percentages vary and must be calculated against the chargeable amount at death.

What are the transitional rules for gifts made from 30 October 2024?

Gifts made from 30 October 2024 where death occurs after 6 April 2026 attract transitional rules that can affect how reliefs apply. These rules aim to phase in the new £1m allowance and changes to relief interaction. The precise effect depends on the date of the gift and the date of death, so each case needs careful timing and record‑keeping.

When does Capital Gains Tax (CGT) matter with lifetime gifts?

Lifetime gifts can trigger CGT because they are treated as disposals at market value for the donor. Gift Hold‑Over Relief can defer CGT where business or agricultural assets qualify, passing the gain to the recipient. Use of hold‑over relief requires careful handling to avoid creating unexpected liabilities.

How can life insurance help manage the cash cost of a future charge?

Life cover can raise funds to meet a charge on death. A seven‑year term policy protects against risks from recent gifts, while whole‑of‑life policies pay out regardless of timing. Policies can be written into trust so proceeds pass outside the estate, providing quick cash to heirs without increasing the estate’s assessed value.

Should cover be fixed‑term or whole‑of‑life when gifting isn’t practical?

If you expect to make significant lifetime gifts and are within the seven‑year window, fixed‑term cover matching that period can be sensible. Where the liability may arise at any time in the future, whole‑of‑life cover gives certainty that a sum will be available on death. Match the policy length and sums to your projected potential liability and rising land values.

How do we keep cover aligned with rising land value and inflation?

Consider inflation‑linked policies or regular reviews and top‑ups of cover. Land values can climb quickly, so arrange policies that allow increases without new medical underwriting or set periodic reviews to adjust sums insured. This avoids under‑insurance when the charge crystallises.

What immediate steps should farming families take now?

Start with a review of ownership, wills and partnership or tenancy agreements. Consider rebalancing ownership where practical. Check existing wills drafted before October 2024 and update them if needed. Speak with a solicitor and chartered tax adviser to model outcomes under the April 2026 rules and to map gifting, trusts and insurance options to your family goals.

Where can we get specialist advice?

Seek a solicitor experienced in agricultural succession and a chartered tax adviser who understands APR and BPR. Look for advisers with farm clients and a track record of handling land, partnerships and succession. We can help you find the right specialists and work alongside them to protect the family land and livelihood.

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help you?

We’re here to help. Please fill in the form and we’ll get back to you as soon as we can. Or call us on 0117 440 1555.

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