A man is walking into a wheat field in the setting sun, checking his crop

Reforms to Inheritance Tax agricultural property relief and business property relief: application in relation to trusts

3 March, 2025

Following the changes to Agricultural Property Relief (APR) and Business Property Relief (BPR) announced at October’s Budget in 2024, HMRC have published a detailed consultation on the implications of the changes for trusts.

From April 2026, the Government has proposed that the amount of property eligible for a 100% rate of APR/BPR will be capped at £1 million. The consultation covers the implications of these changes for trusts from 6 April 2026, including details of transitional rules for existing trusts and anti-fragmentation rules for trusts created after the Budget on 30 October 2024. 

The consultation will run for eight weeks to the 23 April 2025. The ATT will be responding to the consultation and comments and feedback would be welcome to to [email protected] by 14 April 2025.