What has changed?
From 6 April 2026, the government has introduced a £2.5 million cap on 100% Business Property Relief (BPR) and Agricultural Property Relief (APR). Previously, qualifying business assets and agricultural property could benefit from unlimited 100% relief from inheritance tax.
Under the new rules, the first £2.5 million of qualifying assets still attracts 100% relief. However, anything above this threshold will only qualify for 50% relief, meaning an effective inheritance tax rate of 20% on the excess.
Who does this affect?
These changes are particularly relevant for:
- Business owners with trading company shares or assets valued above £2.5 million.
- Landowners and farmers with agricultural property.
- Trustees holding qualifying business or agricultural assets.
Why does this matter?
For many business owners and farmers, BPR and APR has historically been a cornerstone of inheritance tax planning, allowing wealth built up over a lifetime to pass to the next generation without a significant tax burden. The introduction of the £2.5 million cap changes this picture considerably.
Those with business assets above the threshold could face a substantially higher inheritance tax liability than previously anticipated, making early and proactive planning more important than ever.
What should you do now?
The changes have already come into effect, so there is no time to waste. We would encourage business owners, farmers and trustees to:
- Review your current estate and succession plan in light of the new rules.
- Consider whether existing structures remain tax efficient.
- Explore options such as gifting strategies, trusts, or insurance solutions where appropriate.
- Speak to a specialist adviser who understands both your personal and business goals.
How Ballards can help
Our Private Client Tax team works closely with business owners, farmers and trustees to navigate complex tax planning challenges, combining technical expertise with a deep understanding of your wider financial picture.
We don’t just look at the tax. We help you see the full picture and plan with confidence.
Get in touch
If you’d like to discuss what the BPR and APR changes mean for you, please get in touch with our Private Client Tax team at https://ballardsllp.com/personal-tax


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