The changes to Business Property Relief (BR) and Agricultural Property Relief (AR) rules are possibly the biggest and stealthiest changes announced within the budget.
Currently, these reliefs are subject to a lower tax rate than the standard 40% IHT tax charge – typically 0% or 50%. However, the government’s reform of Agricultural Property Relief and Business Property Relief from April 2026 sees the 100% rate of relief reduce to 50% after the first £1 million of combined agricultural and business assets, in hopes to help protect smaller family farms and businesses. The government will also reduce the rate of business property relief to 50% in all circumstances for “not listed” shares on the markets of a recognised stock exchange, such as AIM.
Currently, there is no limit to the BR or AR that an estate can claim – so, for a typical UK business worth more than £1 million, the impact of this budget is significant as their estates will pay an additional 20% tax above the £1 million.
AIM listed shares which currently benefit from BR relief and can be held within an ISA were also widely speculated to change in the lead-up to the Autumn Budget. These will be subject to relief at 50% of BR and therefore subject to 20% IHT taxation from April 2025. However, further details are yet to be released on whether this impacts the BR limit of £1 million or if the ISA wrapper benefit is being removed, and therefore we await further clarification on this topic.
On a positive note, the EIS and VCT schemes were further backed by Labour which we warmly welcome.