Changes to the 100% APR/BPR allowance - a welcome New Year present for trustees too?

Just before Christmas, on 23 December 2025, the Government announced that the new 100% inheritance tax (IHT) relief allowance for individuals making transfers of qualifying business or agricultural property will be £2.5 million from 6 April 2026 rather than £1 million, as originally announced.

We wrote about this announcement on 24 December in our article here.  In that article, we noted that it was not clear from the Government's press release whether the increased allowance would apply only to transfers by individuals, and even then, whether lifetime transfers would be included or only those on death, and whether trustees would also receive the benefit of an increased allowance. 

However, in a paper published today, the Government has tabled a number of new amendments, all relating to the increased allowance, which make clear that it is their intention that the £2.5 million allowance should apply to both transfers on death and lifetime chargeable transfers by individuals, and also to trusts, whether settled before or after 30 October 2024. 

What to do now

While the proposed changes are still to be considered in Committee, they show what the Government intends.  As such, anyone who owns qualifying agricultural or business property should consider whether the increased allowance may affect any planning they have already put in place.  Those still in the planning stages will want to decide whether the recent developments may influence their decision to make transfers or, if relevant, establish trusts or other structures, before the April deadline.

If you would like advice on how and whether the new increased allowance or the changes to BPR and APR more generally may affect you, please get in touch with your usual Howard Kennedy contact, or a member of our Private Client team.