Peter Rayney explores the imminent changes to business property relief and how they affect succession planning in owner-managed companies.
Many owner-managers feel that Autumn Budget 2024 was not business-friendly. The media fallout picked up on the apparent ‘ravaging’ changes to the inheritance tax (IHT) regime, focusing in particular on the restrictions in business property relief (BPR) and agricultural property relief (APR).
The ‘good old days’
Historically, shareholdings in unquoted ‘qualifying’ trading companies have generally been fully exempt from IHT on death, on lifetime chargeable transfers and on failed potentially exempt transfers (PETs) (IHTA 1984, Pt 5, Ch 1). This is because owner-managers have been able to claim 100% BPR provided they held their shares for at least two years, subject to possible restrictions where the
