THE BRIEFING Tax
SIX TOP FARMING & ESTATES LAWYERS
Coming a cropper
Simon Blackburn Wedlake Bell
The chancellor’s attack on inheritance tax relief for
farmers caused panic last autumn. Now the crop dust has settled somewhat, Alec Marsh surveys the damage
Rupert Burchett Payne Hicks Beach
Farmers protest the end of IHT relief in London in March
Edmund Fetherston-Dilke Farrer & Co
THE BRITISH ARE GOOD at gallows humour. Which explains the somewhat wry suggestions in legal circles recently that, following the government’s decision to upend the longstanding relief on inheritance tax (IHT) on agricultural land, the best thing for elderly owners of farming estates to do is to marry their daughter-in- law or son-in-law – ‘so long as the right pre- and post-nup are in place’, of course. An even more extreme – and equally
unserious – suggestion for tax mitigation is, ahem, to take the precaution of dying before 6 April 2026. In that case, one’s whole estate would still get passed on tax-free. ‘We do give clients that option,’ chirps one lawyer, a bit too cheerfully.
Unfortunately, the jokes might also serve as a grim reminder that the suicide rate for farmers was already among the highest in Britain, even before Rachel Reeves announced her reform of agricultural protection relief (APR) and business protection relief at the Budget in 2024. The upshot is that from next April landowners will face a 20 per cent IHT bill on all agricultural land over the value of £1 million. Down at the Hampshire office of legal
firm Moore Barlow, they’re using a notional case study to illustrate the challenge for landowning clients. A 600-acre ‘vanilla Hampshire farm’ valued at £9.5 million is owned by a Bob and Belinda, both in their nineties, and makes an annual profit of
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