Caroline Miller
- Partner
- Private Client
As we move through the 2025/26 tax year, this edition arrives at a pivotal moment for estate planning and wealth structuring. The government has confirmed significant reforms to the inheritance tax reliefs for agricultural property and business property, due to take effect from 6 April 2026. These changes will include a £1 million allowance which caps the amount of assets that can qualify for 100% relief, with any excess attracting only 50% relief — a shift that could have far-reaching implications for landowners, business proprietors and their succession planning. In this edition, we delve further into this topic and provide exclusive guidance for In Trust readers and clients, and action points to consider.
With the Autumn Budget scheduled for 26 November 2025, and speculation continuing around wide-ranging tax reforms, staying informed and prepared is more important than ever. Uncertainty is already being felt in the residential property market, where investor confidence and long-term planning are being shaped by anticipated changes to property taxes — a trend we explore further in this edition.
Trustees, families and advisers alike are navigating a more compliance-driven environment. The government has recently announced proposed reforms to the UK Trust Registration Service including the introduction of a new de minimis threshold for certain newly created small trusts, while also expanding registration requirements to include non-UK trusts holding UK property acquired before 6 October 2020. We will keep you updated as details, including an implementation date, become available.
Against this backdrop, we explore key themes in tax planning, succession and legacy — from the inheritance tax exemption for gifted surplus income to the changing treatment of inheritance tax on pension funds from 6 April 2027, and the importance of structuring with foresight in a climate of reform.
We hope this edition provides a timely and thoughtful overview as you prepare for the months ahead.
In this issue…
- Finance Bill 2025/2026: government confirms Agricultural Property Relief (APR) and Business Property Relief (BPR) reforms effective from April 2026 — the government has confirmed major reforms to agricultural and business property reliefs, including a new £1 million cap on 100% relief and a reduced BPR rate for AIM shares. With the changes set to take effect from 6 April 2026, now is the time to review your estate planning and IHT strategy.
- From nest egg to tax target: pension funds will no longer be exempt from IHT — the government has confirmed that most undrawn pension savings from registered pension schemes will fall within the scope of inheritance tax from 6 April 2027. With the reforms now included in draft legislation as part of the Finance Bill 2025/2026 and further details published, we outline what is changing, who is affected, and practical steps you can take now to prepare for the new rules.
- Could tax reform speculation chill the residential property market? — with whispers of sweeping tax reforms – from stamp duty shake-ups to a potential wealth tax – buyers and sellers alike are holding their breath. As the Autumn Budget looms, explore how speculation alone is already unsettling the residential property market. Could uncertainty be the biggest disruptor of all?
- Unlocking the power of gifts out of surplus income — as the new school term begins, grandparents may be missing a valuable opportunity to support education tax-efficiently. Gifting out of surplus income — when done correctly — can help fund school fees or university costs without triggering inheritance tax. With potential tax changes looming in the Autumn Budget, now is the time to review your options.
- Love, marriage and inheritance: why parents and grandparents should care about pre-nups – when it comes to protecting family wealth, prenuptial agreement can be just as important for the parents and grandparents as it is for the couple getting married. Whether it is a gifted house deposit or a future inheritance, many families are choosing to help fund the cost of a pre-nup.
In the press
- Senior Partner Camilla Wallace has written for FT Adviser on rumours that the government is reconsidering its “non-dom” tax reforms and whether any form of U-turn will come too late to stop the outflow of wealth and talent from the UK. Read more here.
- Partner Kate Johnson is quoted in City AM on the “unreliable” data surrounding non-doms leaving the UK. Read more here.
- Partner and Head of Residential Property Parminder Sidhu responds to a reader’s question on purchasing a property with suspected damp for The Sunday Times. Read more here.
- Partner Oliver Embley featured in eprivateclient discussing how insurance can help manage future inheritance tax liabilities. Read more here.
- Art & Heritage Counsel Clarissa Levi has been quoted in The Telegraph discussing how farmers are designating their land as scenic in a strategic effort to counter the government’s impending inheritance tax measures. Read more here.
- We are delighted that our Private Client team has once again been featured in the Citywealth Leaders List, celebrating 20 years of excellence in wealth management. This recognition reflects our team’s dedication to delivering exceptional service across private wealth law, tax, trusts and estate planning. Read more here.
Meet the team: