
Just before Christmas, the Government confirmed a significant change to the proposed Inheritance Tax rules for agricultural and business assets.
From April 2026, the value of assets that can qualify for 100% Agricultural Property Relief (APR) and Business Property Relief (BPR) will increase from £1 million to £2.5 million per estate.
The change follows strong opposition from farming families and business owners after the original proposal was announced, and it marks a partial retreat from what many saw as a sharp tightening of the rules.
For family farms and owner-managed businesses, this adjustment will offer welcome breathing space. But it does not remove the need for careful planning.
What’s changing from April 2026
Under amendments to the Finance Bill 2025:
- The threshold for 100% APR and BPR will rise from £1m to £2.5m per estate
- Assets above £2.5m will still qualify for 50% relief, provided they meet the conditions
- The relief will remain fixed until at least April 2031
- The allowance will be transferable between spouses or civil partners, meaning a combined relief of up to £5m may be available on second death
- Unused allowance can still be claimed where the first death occurred before April 6 2026
The Government estimates this change will halve the number of estates affected in the first year of the new rules.
Why this matters for Cumbria and rural families
Cumbria has a high concentration of:
- Family farms
- Land-rich, cash-poor estates
- Trading businesses tied closely to land or property
- Multi-generation ownership structures
Under the original £1m cap, many ordinary family farms would have faced significant Inheritance Tax liabilities without selling land or restructuring.
The revised £2.5m threshold protects far more of these businesses, particularly where value is tied up in land, buildings and long-standing trading assets rather than liquid wealth.
That said, larger estates are still firmly in scope, and relief above £2.5m is only partial.
A welcome change, but uncertainty remains
The way these changes have been introduced has caused real difficulty for families.
Over the past year, many business owners have:
- Accelerated succession plans
- Restructured ownership
- Sold land or assets
- Changed wills and partnership arrangements
All of this was done on the assumption that the £1m cap was settled policy.
The late adjustment to £2.5m is helpful, but it does not undo the stress or the irreversible decisions already taken by some families. It also highlights an ongoing issue with tax policy being introduced in stages, creating uncertainty where long-term stability is essential.
What hasn’t changed
It’s important to be clear about what this change does not do:
- It does not remove Inheritance Tax risk altogether
- It does not increase relief beyond £2.5m per estate
- It does not remove the need to meet strict qualifying conditions for APR and BPR
- It does not address concerns about passive land ownership versus active trading use
Reliefs still depend on how assets are used, how businesses are structured, and how long assets have been owned.
What business owners should do now
Even with the higher threshold, doing nothing is rarely the right approach. The increase buys time, not certainty.
We recommend business owners and farming families consider:
- Reviewing current asset values against the new £2.5m threshold
- Stress-testing what happens if values rise before April 2026
- Checking that assets genuinely qualify for APR or BPR under current rules
- Reviewing wills, partnership agreements and shareholder arrangements
- Considering succession planning in stages rather than rushing decisions
- Documenting trading activity clearly, especially where land ownership is involved
Early planning gives more options. Waiting until values exceed thresholds reduces them.
A reminder on long-term planning
Inheritance Tax planning works best when it is:
- Calm, not reactive
- Based on realistic valuations
- Aligned with how the business actually operates
- Reviewed regularly as rules and values change
The latest announcement is a positive step for many families, but it reinforces one core message. Tax rules can change quickly. Good planning is about resilience, not chasing headlines.






