Agriculture and Small Businesses: Inheritance Tax

(asked on 20th November 2025) - View Source

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, pursuant to WPQ 80434 answered on 17 October 2025, what assessment she has made of the potential merits of the proposals on the (a) minimum share rule, (b) upper limit on relief and (c) transferrable allowance in that report.


Answered by
Dan Tomlinson Portrait
Dan Tomlinson
Exchequer Secretary (HM Treasury)
This question was answered on 28th November 2025

The Government believes its reforms to agricultural property relief and business property relief from 6 April 2026 get the balance right between supporting farms and businesses, and fixing the public finances. The reforms reduce the inheritance tax advantages available to owners of agricultural and business assets, but still mean those assets will be taxed at a much lower effective rate than most other assets. Despite a tough fiscal context, the Government will maintain very significant levels of relief from inheritance tax beyond what is available to others and compared to the position before 1992. Where inheritance tax is due, those liable for a charge can pay any liability on the relevant assets over 10 annual instalments, interest-free.

As announced at Budget 2025, any unused £1 million allowance for the 100% rate of agricultural property relief and business property relief will be transferable between spouses and civil partners, including if the first death was before 6 April 2026.

The report by the independent Centre for the Analysis of Taxation (CenTax) sets out its other potential amendments to the policy are not, in its own words, a “silver bullet”. For example, CenTax acknowledge the proposal for a minimum share test is less effective than the Government’s reforms in raising revenue from the wealthiest estates, could be exposed to tax planning opportunities, would not necessarily prevent wealthy individuals buying land for inheritance tax purposes, and would mean double the number of estates being affected by the reforms (and largely estates below £2 million).

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