100 percent relief on the first £1m of qualifying assets. 50 percent above £1m. A separate 50 percent rule for AIM and other not-listed shares. What it means, who it affects, and what to gather before the October Budget.
You built a business worth £3.5m. Maybe an engineering firm, a recruitment agency, a chain of shops, a farm that's been in the family for three generations. You have spent twenty years or more getting it there. The plan was always that it would pass on intact. That plan may now be wrong. The rules around Business Property Relief and Agricultural Property Relief changed on 6 April 2026. The change is not in the detail. The change is in the headline number.
This page is the case for treating that change seriously, in the next four weeks, before the 28 October 2026 Autumn Budget. It is the tactical counterpart to the wider IHT planning tools round-up. The page is the rule change and the one monthly action. Read them in either order.
For decades, a family business or a working farm could pass from one generation to the next with little or no Inheritance Tax to pay, provided the business was a genuine trading business and the owner held it for at least two years. Most advisers called it "the family business exemption." Many families relied on it without checking the small print.
The April 2026 reform did not remove BPR or APR. It changed the rate. The first £1m of combined qualifying business and agricultural property still attracts 100 percent relief. Above £1m, the relief is now 50 percent, not 100 percent. The same 50 percent rule applies in all circumstances to AIM shares and other "not listed" qualifying shares. The change is narrow on paper. For a £3.5m business, the numbers are not narrow at all.
Business Property Relief (BPR) is the Inheritance Tax relief that applies to certain business assets. It covers shares in an unlisted trading company, a sole trade or partnership interest, and certain business property such as a building used by the business. Source: HMRC Inheritance Tax Manual.
Agricultural Property Relief (APR) is the equivalent for qualifying agricultural property. It covers the agricultural value of land and certain farm buildings, depending on how the land is used and who occupies it.
The word "qualifying" matters. Not every asset that looks like a business or a farm qualifies. A trading company that also holds large investment portfolios, a let farm that does not pass the occupancy test, or a personal service company can all lose relief. Source: HMRC Inheritance Tax Manual. The relief is not automatic. The relief is checked.
BPR and APR are also not the same as the ordinary Inheritance Tax allowances. The £325,000 nil-rate band and the £175,000 residence nil-rate band are still there, with the same conditions. BPR and APR sit on top of them. Source: GOV.UK Inheritance Tax overview.
The headline numbers, in the order the rules apply:
| Asset or position | Treatment from 6 April 2026 |
|---|---|
| First £1m of combined qualifying business and agricultural property | 100 percent relief |
| Qualifying business and agricultural property above £1m | 50 percent relief |
| Qualifying "not listed" shares, including AIM | 50 percent relief in all circumstances |
| Standard IHT nil-rate band | £325,000 per person |
| Residence nil-rate band (where it applies) | £175,000 per person, tapered above £2m |
| Standard IHT rate on the taxable amount | 40 percent |
It does not mean every business owner now owes 40 percent on the whole estate. The £1m 100 percent slice, the nil-rate band, the residence nil-rate band, the spouse or civil partner exemption, and any qualifying lifetime gifts all still apply.
It also does not mean every farm or every company automatically qualifies. Eligibility is checked against how the asset is held, how it is used, and who owns it. Source: HMRC Inheritance Tax Manual.
Below is an illustrative example. It is not a forecast. It is not advice. The real number for any estate depends on ownership, valuation, debts, lifetime gifts, and the wider family situation.
Illustrative example
Assume a single estate, with no spouse or civil partner transfer available, no residence nil-rate band claimed in the first illustration, no debts, and no lifetime gifts:
The maths
That £570,000 sits in the same family balance sheet as the business itself. It is the number that changes if the ownership changes, if a lifetime gift is made, if the spouse exemption applies, if the residence nil-rate band is in scope, or if any of the assets do not in fact qualify.
A common misunderstanding is that a £2.5m business will be a £1m tax problem. The number is not a clean ratio. It depends on what the estate actually contains, which assets qualify, and how the ownership is structured. The example above shows a £570,000 figure for one set of assumptions. Change one assumption and the figure moves materially.
The change is wide but the impact is not evenly spread. The situations that most need a closer look, in priority order:
Above £1m, every additional pound of qualifying value is half-relieved, not fully relieved. The exposure grows with the value.
First-death and second-death outcomes matter. The spouse or civil partner exemption can pass the unused £1m slice forward, but only if the will and the ownership are aligned.
The 50 percent rule applies in all circumstances. There is no £1m 100 percent slice for these shares.
Mixed companies can lose part of their BPR. The investment element is not automatically protected.
If the value has grown quietly over the last ten years, the qualifying value may be larger than the owner remembers.
The change is real. It is not the end of the conversation. The remaining routes are not guarantees, and they are not "loopholes." They are the standard tools an estate planner works with, applied to a different relief landscape. The next move is to know which apply to the reader's situation, and to know the cost and the trade-off of each.
Before 22 September 2026, get the numbers and the documents in one place. The exact decision can wait. The preparation cannot.
For a first-pass estimate of the IHT exposure on the rest of the estate, the inheritance planning check is a starting point. It does not model BPR and APR eligibility, which is fact-specific, but it will show the headline number. For the wider picture of whether the rest of the financial position is on track, see am I on track financially.
A note on this page
Rules last checked against GOV.UK on 3 August 2026 (Autumn Budget 2024; GOV.UK Inheritance Tax overview; HMRC Inheritance Tax Manual). The 28 October 2026 Autumn Budget may change the picture further. The page is financial guidance, not financial advice. Eligibility for BPR and APR is fact-specific and the right next step is a regulated adviser plus a solicitor or tax adviser.