Julia Lewis and Daniel Watson navigate BPR changes in Business & Accountancy Daily
Julia and Daniel’s comments were published in Business & Accountancy Daily, 31 March 2026, and can be seen here.
Julia Lewis, Partner, and Daniel Watson, Senior Associate in our Private Client department, outline how the upcoming changes to Business Property Relief (BPR), effective from 6 April 2026, will reshape the landscape for families operating trading businesses.
They explain that while BPR and Agricultural Property Relief will continue to offer 100% relief, this will now apply only up to a combined £2.5 million cap per individual, with any value exceeding that amount qualifying for 50% relief. They emphasise that businesses must continue to satisfy the two‑year ownership requirement and remain genuinely trading rather than investment‑based. In addition, they highlight the heightened importance of identifying and managing excluded assets such as surplus cash that may prevent part of the business from attracting relief.
The authors then illustrate how these reforms could significantly increase inheritance tax exposure, particularly for high‑value companies or businesses owned by a single individual. Through worked examples, they demonstrate how restructuring ownership between spouses can meaningfully reduce tax liabilities, and encourage early, proactive planning to prepare for the forthcoming changes. They also highlight the strategic advantage of retaining BPR‑qualifying assets until death, noting the benefit of a capital gains tax uplift that would be lost if the assets were sold during lifetime. Practical issues such as setting aside funds, borrowing to meet future liabilities, or avoiding clawback where gifted assets cease to qualify within seven years are presented as essential components of long‑term planning.
Finally, Julia and Daniel explore what the changes mean for wills and trust arrangements. They underline the continued importance of discretionary will trusts, which allow executors flexibility when distributing business assets without triggering unnecessary tax charges, and they note new opportunities arising from the refreshed seven‑year allowance for lifetime transfers into trust. The authors stress the growing need for updated valuations, possible restructuring of ownership interests, and a review of life policies to ensure sufficient coverage under the revised regime. They conclude by encouraging business owners to revisit their estate planning now so that wills, trusts and succession strategies remain aligned with the new relief limits and legislative framework.
Read the full article on the Business & Accountancy Daily website, [subscription required].