Consultation response: Reforms to Inheritance Tax

The ATT has responded to the HMRC consultation document Reforms to Inheritance Tax agricultural property relief and business property relief: application in relation to trusts issued on 27 February 2025.

In our response, we expressed our disappointment that the consultation was restricted to technical matters, and that the Government did not provide any opportunity to discuss or consult on the wider approach to amending or restricting the current reliefs on agricultural and business assets. These changes will have a significant impact on those affected. 

We think that the main areas of technical complexity with the proposals will arise from the anti-fragmentation rules which are intended to apply to all trusts from 30 October 2024. We look forward to commenting on the draft legislation setting out how these rules will operate in detail, which the Government has said will be published later in the year.