HMRC tax rule change on April 6 ‘time-bomb’ for one group of people | Personal Finance | Finance

The clock is ticking on the Government’s inheritance tax (IHT) “time-bomb” for farmers, professionals from an accountancy and advisory firm have cautioned. The manner in which the changes were revealed has generated considerable frustration amongst both industry experts and farmers, with demonstrating farmers gathering in central London to voice their concerns on multiple occasions throughout last year and into late 2024.

Through legislation set to be implemented via the Finance Act 2026, fresh limitations will be imposed on the extent of Agricultural and Business Property Reliefs accessible to farmers passing away after April 5, 2026, as the new HMRC tax year commences. This could result in rural households being compelled to dispose of land that may have remained in their possession for generations.

The modifications mean that 100 per cent Agricultural Property Relief and Business Property Relief will solely cover £2.5m of qualifying assets, per individual, with 50 per cent relief covering the remainder.

Farmers presently face no inheritance tax liability on agricultural and business assets which they transfer. The relief had initially been suggested at £1million, but the farmers’ demonstrations prompted the Government to offer concessions.

Declaring the tax relief threshold increase, Environment Secretary Emma Reynolds said the Government had “listened closely to farmers across the country and we are making changes today to protect more ordinary family farms”. “It’s only right that larger estates contribute more, while we back the farms and trading businesses that are the backbone of Britain’s rural communities,” she added.

Rebecca Colmey, director of Tax Advisory, Farming and IHT at Azets, based in their Tamworth office, said: “The problems began immediately following the 2024 budget when the restrictions were announced without any detail. The restrictions were effective immediately for gifts made post budget day, if the farmer were then to die post-April 6, 2026, but within seven years of their gift, and so prompted the need for advice and action.

“But there was no certainty as to the legal form of the changes until the draft legislation was finally made available on July 21, 2025. “Our team were surprised that the draft legislation ignored the recommendations within the House of Commons’ Report of May 16, 2025 – The Vision of Farming.

“It recommended a more generous level of Agricultural Property Relief to be made available to genuine farmers rather than a blanket lower level of relief to all, including investors in agricultural land. We then had changes in the 2025 budget allowing the transfer of unused allowances between spouses, followed in December by the announcement that the £1m limit was to be increased to £2.5m per individual.”

Robert Anderson, a Partner at Azets’ Coventry office, added: “We meet farmers every week and the stress and worry the policy is causing is undeniable. Most viable farming enterprises have a value per head in excess of £2.5 million and we have a lot of clients impacted by this change.

“Some of the older famers feel guilty that if they live beyond April 5 they are somehow letting their families down and consider it unfair that they haven’t been allowed time to do any planning. Many are asset-rich, but cash-poor, and so acknowledge that parts of their farms may need to be sold to fund the inheritance tax liabilities.

“This is a complicated issue and it’s not as easy as just giving some land away and then hoping you live beyond the seven-year rule when it is free from IHT. Trusts have been proposed as a planning option, but they won’t suit all farms and are complex – every single case is different and there is no off-the-shelf solution.

“Careful planning must be undertaken with consideration given to the current and intended future use of each part of the farm. We recommend that, if they haven’t already done so, farmers seek good financial and legal advice as soon as possible in order to get proper planning in place and to best mitigate against the tax.

“One of our fears is that there are farmers out there who are tempted to just bury their heads in the sand and hope the problem goes away. While we understand the uncertainty caused by the way the restrictions have been introduced may make farmers hopeful that further changes could be announced, time is running out. Farmers need to understand how this will impact them, their families and their farms and how best to manage this, and the best way is to get expert advice that is tailored to their situation and circumstances.”