Inheritance Tax: Family-owned Businesses

Tuesday 3rd June 2025 Westminster Hall

16:44

[Sir John Hayes (in the Chair)]

I will call Susan Murray to move the motion, and then the Minister to respond. I remind other Members that they may make a speech only with permission from the Member in charge of the debate and the Minister.

[Susan Murray (Mid Dunbartonshire) (LD)]

I beg to move,

That this House has considered the impact of Inheritance Tax on family-owned businesses.

It is a pleasure to serve under your chairship, Sir John, and a privilege to lead this debate on a matter of real consequence to our economy. I begin by paying tribute to the extraordinary contributions that family-owned businesses make across the country, not least in my own Mid Dunbartonshire constituency. They are not just economic actors; they are part of the fabric of our communities. They offer good local jobs and apprenticeships, sponsor local sports teams, support local charitable activities, and keep our high streets and industrial parks alive with character, energy and local pride.

According to the Fraser of Allander Institute, in 2025 family-owned businesses are in turbulent and uncertain times. They are facing national insurance increases, with many scaling back plans for workforce expansion and recruitment as a result. The latest quarterly economic indicator from the Scottish Chambers of Commerce network presents a stark picture, as businesses face pressure that threatens to derail growth, investment and competitiveness. Taxation is now the No. 1 concern facing Scottish businesses.

[Jim Shannon (Strangford) (DUP)]

I commend the hon. Lady on securing this debate. She is absolutely right to highlight the issue of taxation. Does she agree that taxing businesses at 20% based on their value at the time of the owner’s death cannot possibly take into account the owner’s personal input into the business, and leaves a situation that can run a successful business into the ground? There is only so much that one person can be taxed before the burden is too great, and the taxation the Government are pushing is definitely going to destroy the farming sector.

[Susan Murray]

I thank the hon. Gentleman for raising that issue; I completely agree.

The Centre for Economics and Business Research found that nine out of every 10 privately owned businesses in the UK are family owned, and that they provide employment for nearly 16 million people and contribute more than £200 billion in taxes annually.

[Dame Harriett Baldwin (West Worcestershire) (Con)]

The hon. Lady is making an excellent speech and I congratulate her on securing this important debate. Did she see the research published yesterday by Family Business UK, which points to the disastrous impact of the inheritance tax reforms on family-owned businesses? In my West Worcestershire constituency alone, the changes will lead to a reduction of £18 million of gross value added and of 286 full-time equivalent jobs.

[Susan Murray]

I thank the hon. Member for raising that issue. I have seen the research and will refer to it later in my speech. That was a timely publication.

[Graham Stringer (Blackley and Middleton South) (Lab)]

I am grateful to the hon. Lady for being generous on this important issue. When she spoke about the contribution that family businesses make, she could have been talking about J. W. Lees, a brewery in my constituency that has a nearly 200-year history of making contributions to the local community and brewing very good beer, or to Joseph Holt, which is on the edge of my constituency. The Confederation of British Industry estimates that the proposed changes to business property relief will lose the Government nearly £1.9 billion. Does the hon. Lady agree that before the Government go through with the changes, they should have a consultation that looks at the impact on tax and local family businesses?

[Susan Murray]

I completely agree: it appears that there are many factors the Government have not taken into account.

The situation was brought home to me by a local company in my constituency: Archibald Young Ltd Founders and Engineers, a family-run foundry that has been operating in Kirkintilloch since 1959—not quite as long as the business mentioned by the hon. Member for Blackley and Middleton South (Graham Stringer). I thank Ian Young for sharing his company’s position and highlighting the vital role that it plays in defence by producing high-precision critical components. Since it was established, the company has grown steadily over three generations. At one time, Scotland had over 260 foundries; it now has 12, of which 11 are family-owned, and all are third generation.

[Sir Edward Leigh (Gainsborough) (Con)]

The hon. Lady is making an excellent speech. Will she make the point that we do not really understand where the Government are coming from? I understand why they want to claw back money from big estates, or from people who buy farms just to avoid inheritance tax—not Jeremy Clarkson of course; he is a fantastic chap—but I cannot understand why they are focusing on family farms. Will the hon. Lady make the point that the National Farmers Union has offered various compromises, and the Minister should meet the NFU in a positive way to ensure that we keep our family farms run by families?

[Susan Murray]

I agree; it is important we understand that these businesses and family farms exist in their own right and are not simply personal property, even though they are family owned.

Today, under Andrew Young, Young’s foundry continues to provide skilled and specialist manufacturing from its bases in Kirkintilloch, Motherwell and the north of England. Like so many of the family-run firms we are here to talk about, its success has been built over decades of hard work and reinvestment in its business and workforce, yet recent Government policies are putting that at risk.

Clearly, family-owned businesses can cope with challenges in the economic and business environment, which they have navigated over generations, but when Government policies are hostile to their success and survival, their ability to create jobs and grow the economy is eroded and their future is uncertain. Whether it is rising energy and employment costs, burdensome business rates or disproportionate regulatory hurdles, these enterprises face challenges that their multinational competitors are often better equipped to absorb, or that they do not face at all.

The reforms to business property relief and agricultural relief announced in the 2024 autumn Budget have dealt family businesses a blow that risks undermining the very principle of intergenerational succession that has been at the heart of their success. They must retain profits to reinvest in business assets, to enhance business competitiveness and invest in product development.

Prior to the reforms, the shares held in private family-owned businesses could be passed on upon death to the next family generation, free of inheritance tax. This was enabled by the shares qualifying for 100% business property relief. The 2024 Budget introduced a new £1 million relief cap beyond which inheritance tax is due, with business property relief of 50%, resulting in an inheritance tax charge of 20% being applied to such transfers upon death. This sudden change means that family financial planning opportunities are much more limited. Under the new rules any lifetime transfer of business property relief or agricultural property relief assets made on or after 30 October 2024 will be subject to the new relief limits if the donor dies on or after 6 April 2026.

GAP Holdings Ltd is another family-owned business based in my constituency. I thank Mark Anderson of GAP for allowing me to share his company’s position in this debate. He has also met the Secretary of State for Business and Trade and colleagues. Founded in 1969, GAP’s tool-hire business has grown dramatically. By reinvesting in its assets over the past 10 years, it has tripled its turnover and now employs over 2,000 people across the UK. GAP’s annual profit to March was £44 million, and its earnings before interest, taxes, depreciation and amortisation were £132 million. For GAP, the potential inheritance tax charge arising upon the death of the second generation would amount to tens of millions of pounds. The proposed £1 million relief cap would make no meaningful difference to the size of the problem. Three months ago, GAP exceeded the £1 million mark in its total donations to charitable causes. That is the kind of benefit that these businesses bring to the community.

The inheritance tax changes would require the independent valuation of companies. Will the Minister clarify whether there is a consistent and defined methodology for that activity? When a family business owner dies and leaves shares to the next generation, there is no cash available to pay inheritance tax liability and no windfall to successors. In practical terms, it is business as usual, and the business continues to use its assets to trade and contribute economically to the local community. It is not the same as selling a business; however, it may force the company to be sold completely to pay the liability.

Will the Minister confirm that it is not the Government’s intention that a family-owned business that has been passed down through the generations is forced to be sold as a result of the change, or forced into failure by having to take on unsustainable levels of debt?

[Graeme Downie (Dunfermline and Dollar) (Lab)]

I congratulate the hon. Lady on securing this debate on a very important issue. Like herself, I have spoken to GAP, as well as other family businesses in my constituency. Does she agree that although the Government are absolutely right to ensure that we have enough funding to pay for public services through tax changes, one option might be to allow businesses to pay inheritance tax in the way proposed if that business is passed on to another family member, so that the tax liability is still met, but in a way that does not impact on future generations and allows the businesses to succeed and thrive?

[Susan Murray]

It is important to look at all ways to make sure we have a system that does not cause the demise of family-owned businesses.

[Mr Alistair Carmichael (Orkney and Shetland) (LD)]

I could be wrong, but I am pretty sure that the guidance from His Majesty’s Revenue and Customs states that, at present, where there is 100% relief, valuations for BPR are done on the basis of the book value, which is, as my hon. Friend will know, often very different from an asset’s actual value. That being the case, I wonder how easy it would be for the Government to have reached any reasonable understanding of the actual value of the assets that they now seek to tax.

[Susan Murray]

That was the point I was making when I asked the Minister whether there is an established methodology to make sure that the valuation of companies reflects the current situation.

This change does not target the ultra-wealthy or global conglomerates. In many parts of the UK even modest enterprises, especially those with land and equipment, which are often the biggest local employers, exceed the £1 million relief cap. Unlike large corporations, family businesses cannot just offshore ownership structures or use complex tax arbitrage to avoid the costs.

I am sure that every Member present, including the Minister, agrees that preserving the businesses at the heart of our communities should be the Government’s priority, not erecting barriers that create an environment too toxic for family businesses to survive. Will the Minister consider raising the relief cap to £2 million, as requested by the Scottish Chambers of Commerce network? That would make more family businesses exempt from this dangerous inheritance tax, thereby protecting jobs and local businesses.

The reality is that the Government have not undertaken an impact assessment, and according to estimates by the Office for Budget Responsibility, the changes to business property relief and agricultural property relief will raise only around £1.8 billion over a four-year period. That amount comes with a high uncertainty rating, because behaviour change might alter it significantly, and it cannot be compared with the £27 billion of VAT, late PAYE and national insurance that HMRC is yet to collect.

Forcing family businesses to reduce investment, withdraw capital, dispose of assets or sell or shut their business entirely to release cash to fund inheritance tax liability will weaken the competitiveness of not only the businesses themselves, but the wider UK economy. The changes may be well-intentioned, but they are misdirected in their execution. They risk treating genuine business owners in the same way as passive investors, and in doing so they ignore the fact that these reliefs were originally designed to protect the continuity of real working businesses in real communities.

In conclusion, will the Minister consider amending the proposed legislation to ensure that the changes do not weaken genuine family businesses—

[Carla Lockhart (Upper Bann) (DUP)]

The hon. Member is making a very powerful speech. Before she closes, it is important for us just to home in on the figures. A Family Business UK report shows that in my constituency the changes to business property relief and agricultural property relief will result in a £23.63 million reduction in gross value added and the loss of 381 full-time equivalent jobs, as well as being the end of many family farms. Multiplying those figures out across the United Kingdom means the loss of 208,000 jobs, a £14.8 billion reduction in GVA and a net fiscal loss to the Government of £1.9 billion. Does she agree that the death tax is immoral and should be scrapped?

[Susan Murray]

I certainly agree that we need to protect our family-owned businesses and do everything we can to help them to thrive, rather than putting them in a position whereby the economy is at risk of losing both jobs and growth.

I will finish the question that I was putting to the Minister. Will he consider amending the proposed legislation to ensure that the changes do not weaken genuine family businesses, and make the transfer of shares in a family business to the next generation exempt from inheritance tax for seven years, provided that the business is not sold in that period? If it is sold within that period, inheritance tax would become payable, along with the capital gains tax, both of which could be funded from the proceeds of the sale.

This Government have stated that growing the UK economy is essential, but attacking the backbone of the economy—the family businesses that have proved they can adapt and change rapidly to meet changing market needs and conditions, and that support supply chains and local jobs—must not happen. Family businesses should be supported, not raided for a relatively de minimis gain to the Exchequer.

[Sir John Hayes (in the Chair)]

Before I call the Minister, I hope he will leave me a couple of moments at the end of the debate to put the question.

17:03

[The Exchequer Secretary to the Treasury (James Murray)]

It is a pleasure, Sir John, to speak in this debate with you as Chair, and I congratulate the hon. Member for Mid Dunbartonshire (Susan Murray) on securing it—I notice that the debate is being opened and closed by a Murray.

I know that some Members are very concerned about the impact of forthcoming reforms to inheritance tax reliefs on businesses in their constituencies, and I understand that people feel very strongly about inheritance tax. I should be clear that the Government believe that our reforms to business property relief and agricultural property relief get the balance right between supporting farms and businesses and fixing the public finances in a fair way. The reforms reduce the inheritance tax advantages available to owners of agricultural and business assets, but still mean that those assets will be taxed at a much lower effective rate than most other assets.

Let me make clear that, much like the hon. Lady set out, the Government recognise and greatly value the huge contribution that small and family-owned businesses make to their communities and the economy. Businesses large and small, including family businesses, will create jobs and wealth and be the engines of growth in the economy. Those businesses and their workforces are the backbone of our economy, and they are fundamental to kickstarting economic growth, which is the Government’s No. 1 mission. Those businesses need a Government who will take the right decisions in the national interest, including when they are difficult, to support our security and prosperity.

People who own, run and work in businesses of all sizes will remember the economic context that we inherited last year. They know how important responsible financial management is within their own businesses and how the success of businesses and their workforces depends on economic stability and public services that function well. I believe that many of them will understand that, since taking office, the Government have taken a number of difficult but necessary decisions on tax, welfare and spending to restore economic stability, fix the public finances and support public services. None of these decisions, including the decision to reform agricultural property relief and business property relief, was taken lightly, but those tough decisions were left to us by the previous Administration, and no responsible Government could have let things carry on as they were.

Alongside our work to stabilise the economy and restore discipline to the public finances, the Government are determined to do everything we can to support businesses to grow. We are overhauling the UK’s regulatory system to reduce burdens on businesses by 25% by the end of this Parliament. We have secured trade deals that will slash the cost of doing business abroad, reduce border checks, cut tariffs and axe red tape. Those trade deals will support jobs and create opportunities for Great British businesses in our biggest current markets and in one of the world’s biggest future markets, too.

The Government expect to publish an SME strategy later this year. It will set out the Government’s vision for SMEs, from encouraging entrepreneurship to boosting scale-ups across key policy areas, such as creating thriving high streets, making it easier to access finance, opening up overseas and domestic markets, building business capabilities and providing a strong business environment.

Despite the tough fiscal inheritance at the election last year, we have also taken decisions to continue supporting small businesses through the tax system. We have chosen to increase the employment allowance to £10,500 to take many small businesses out of paying national insurance contributions altogether. We froze the small business rates multiplier to protect small properties from inflationary bill increases, and we will introduce permanently lower business tax rates for small retail, hospitality and leisure businesses from 2026.

[Anna Gelderd (South East Cornwall) (Lab)]

In rural and coastal communities such as South East Cornwall, family-run businesses and farms are the backbone of the local economy. Does the Minister agree that any changes to inheritance tax must be carefully shaped to support our local businesses and farms to plan for their future so that they can pass on their hard-earned success?

[James Murray]

My hon. Friend is a great champion of businesses and farmers in her constituency. When we were deciding how to reform agricultural property relief and business property relief, we made sure that generous tax reliefs still existed in the tax system precisely because we want to continue to support small and family-owned farms and businesses in particular. I will come to those in a moment.

I am conscious that you asked me to give you a few moments at the end, Sir John. Do you mean at the end of my remarks?

[Sir John Hayes (in the Chair)]

I need about 15 seconds at the very end of your remarks.

[James Murray]

Got it. To conclude my remarks on the wider support that we are giving to businesses, I also draw hon. Members’ attention to the fact that we committed in the “Corporate Tax Roadmap”, which was published at the autumn Budget, to maintain the small profits rates and marginal relief at their current rates and thresholds, as well as the £1 million annual investment allowance.

I know that many Members are concerned about the reforms to inheritance tax that are the subject of the debate, so I will now turn to them. The reality is that the full, unlimited relief introduced in 1992 has become unfair and unsustainable, particularly in the economic context that we inherited. Under the current system, the 100% relief on business and agricultural assets is heavily skewed towards the wealthiest estates, which is clear from the latest HMRC data from 2021-22. More than 50% of business property relief was claimed by just 4% of estates making claims. That means that the wealthiest few per cent of estates claimed £558 million in tax relief. That contributes to the very largest estates paying a lower average effective inheritance tax rate than smaller estates. It is neither fair nor sustainable to maintain such a large tax break for such a small number of claimants, given the wider pressures on the public finances. It is for that reason that the Government are changing how we target agricultural property relief and business property relief.

Under the reformed system, estates will still benefit from 100% relief for the first £1 million of combined assets from April 2026, and on top of that there will be an uncapped 50% relief on further assets. That means that inheritance tax will be paid at a reduced effective rate of up to 20%, rather than the standard 40%. Those reliefs sit on top of the standard nil-rate bands and other exemptions, such as transfers between spouses and civil partners.

[Susan Murray]

Why do the Government not consider taxing large digital multinational corporations trading in this country in order to raise the extra revenue that is being raised from this measure, which effectively punishes the businesses that run the supply chains that export to those markets? Those businesses have relationships with specialist suppliers and are being put at risk.

[James Murray]

I believe that the hon. Lady is asking about the taxation of large multinational firms operating in the digital space. I am sure that she is aware of the digital services tax, which is currently in operation. The Government are committed to maintaining that until the pillar 1 international solution is implemented, and I am sure that she is familiar with pillar 2 of the OECD deal on a global minimum corporate tax rate. Large multinational firms are well dealt with on the international level, which is why, in opposition and in government, we have supported the OECD’s two-pillar solution.

I do not want to be distracted from the design of the reforms that we are talking about today. Where inheritance tax is due, those liable for a charge can pay any liability on the relevant assets over 10 annual interest-free instalments. That benefit is not seen anywhere else in the inheritance tax system.

There has been a lot of discussion of the impact of this policy, so let me set out the numbers, based on HMRC claims data. It is expected that, under these reforms, about 1,500 estates claiming only business property relief will pay more inheritance tax in 2026-27. Two thirds of those estates—about 1,000—are expected to only hold shares designated as not listed on the markets of recognised stock exchanges, such as the alternative investment market. Under these reforms, about three quarters of estates claiming business property relief in 2026-27, excluding estates only holding shares designated as not listed, will not pay any more inheritance tax in 2026-27.

The reforms to relief have generated a lot of commentary about the wider impacts, but hon. Members should take care when relying on analysis based on self-selecting surveys from members of representative groups campaigning against the reforms. Indeed, the independent Office for Budget Responsibility is clear that it does not expect this measure to have any significant macroeconomic impacts, and it certified the costing at autumn Budget 2024. It said that the reforms to agricultural property relief and business property relief are forecast to raise a combined £520 million in 2029-30.

[Richard Baker (Glenrothes and Mid Fife) (Lab)]

I recognise the need for the Government to raise funds, given the economic context that they inherited, but, as my hon. Friend the Member for Dunfermline and Dollar (Graeme Downie) said, a number of family businesses have come forward with alternative proposals that would raise the funds in a different way. Would the Minister and his team be prepared to meet and consult with family businesses to ensure that they have input into the plans? That would enable those businesses to inform them of their experiences and raise alternative proposals that might raise funds differently.

[James Murray]

I reassure my hon. Friend that I, and the wider team of officials, have had a number of meetings with representatives of family businesses and the agricultural and farming sector. We have listened to ideas raised by a number of people we have met, as well as ideas raised in debates in the Commons and in meetings in the Treasury and elsewhere. We have listened, but we remain confident that our approach is a fair way to balance supporting farms and businesses with fixing the public finances, so we stand by our reforms.

I should probably conclude. I thank all hon. Members, particularly the hon. Member for Mid Dunbartonshire, for their contributions to the debate.

Question put and agreed to.