Changes to APR and BPR for trustees

Changes to APR and BPR for

BURGES SALMONChanges to APR andBPR for trusteesThe government’s announced changesto agricultural property relief (APR) andbusiness property relief (BPR) mean thattrustees owning APR and BPR eligibleassets may have IHT charges for thefirst time or increased IHT charges.What is changing?Trustees will have a cap on the APR and BPRthey can claim at 100%. Any value in excess ofthis cap will only get relief of 50%. This meansthat for the first time many landowning orbusiness owning trusts will be subject toongoing IHT charges.When is it changing?The changes apply from 6 April 2026. Quitewhen depends on the type of trust and when itbegan. Trustees should take advice now onwhat may need to be done before April 2026.This flyer summarises some of the key changesas well as providing some starter questions fortrustees to be thinking about.What else to considerTax issues are likely to be one of many factorsas trustees consider the future of a trust. Forsome trusts with illiquid assets, suddenly havingto pay IHT or having to pay more IHT may beunaffordable. These trusts may need to eithersell assets or be brought to an end.For other trusts, the ongoing IHT charges maybe affordable, particularly given that any IHT onproperty that will then only get 50% relief can bepayable in 10 yearly instalments.Alongside any IHT issues, trustees will alsoneed to consider:• the wider purpose of the trust;• the beneficiaries’ needs;• trust terms;• any letter of wishes of the settlor; and• wider benefits of asset protection and controlthat trusts provide.How we can helpBurges Salmon has extensive experienceadvising family businesses and landownerswhether that property is held personally or bytrustees.Our private wealth team can assist with taxadvice, estate planning, family advice, corporateadvice, and property advice.We are able to advise you on these issues as awhole or work alongside your existing advisorsto guide you through what the options might befor your business or land ahead of the changesnext April.Tom HewittPartnerT: 0117 902 2717E: tom.hewitt@burges-salmon.comAndrew KerrSenior AssociateT: 0117 307 6849E: andrew.kerr@burges-salmon.comwww.burges-salmon.com