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IHT · Business Property Relief · 2026/27

IHT Business Property Relief (BPR) explained (2026/27)

BPR can wipe out IHT on qualifying business assets entirely. Trading businesses, unquoted shares (including AIM-listed) get 100% relief; controlling interests in listed companies and certain assets used in your business get 50%. This page covers what qualifies, the 2-year ownership rule, the "wholly or mainly" trading test, and the 2026 Budget changes that take effect from April 2026.

5-minute read

BPR in one paragraph: qualifying business assets get either 100% or 50% IHT relief, separate from the nil-rate band. Most relevant categories: an unincorporated trading business (100%), unquoted shares including AIM-listed (100%), controlling holding in a quoted company (50%), and land/buildings/machinery used in a business you control (50%). You must have owned the asset for 2 years before death (or transfer). Note: from April 2026, BPR/APR combined relief is capped at £1m at 100% rate; above that, 50% relief applies.

The two rates of BPR

Asset typeRate
Unincorporated business or interest in one (sole trader, partnership)100%
Unquoted shares (including AIM-listed)100%
Shares giving control (over 50%) of a quoted company50%
Land, buildings, machinery or plant used wholly/mainly for the purposes of a business you control50%
Land, buildings, machinery or plant used in a partnership of which you were a partner50%

What does NOT qualify for BPR

The relief targets active trading businesses. Several categories are excluded:

The "wholly or mainly" trading test

For BPR to apply to a company's shares, the company must be carrying on a trade as opposed to being "wholly or mainly" an investment business. HMRC uses several tests, including:

HMRC's rule of thumb is approximately 50% threshold — if more than 50% of the business is investment by these tests, the company fails. The leading case is Brander v Revenue and Customs (2010) on a mixed estate with farming and let property.

AIM-listed shares are technically "unquoted" for IHT purposes (AIM isn't a "recognised stock exchange" for IHT). So most AIM shares qualify for 100% BPR after 2 years of ownership. This has spawned a significant industry of "AIM IHT portfolios" run by investment managers like Octopus, Puma, and Unicorn.

Practical points:

The April 2026 BPR reform

The October 2024 Budget announced a major BPR reform effective from April 2026:

Impact on a £5m AIM portfolio:

The reform is the biggest IHT change in over a decade and significantly impacts estate-planning strategies dependent on BPR.

The 2-year ownership rule

BPR requires you to have owned the qualifying asset for at least 2 years immediately before death (or transfer). Exceptions:

For estate planning: start the 2-year clock now. Don't wait until terminal diagnosis — many BPR strategies fail the 2-year test by being implemented too late.

Worked example: family business owner

Mr K owns 100% of a UK trading company worth £4m. He has a separate £3m investment portfolio and a £1.5m house. He dies in May 2026 (post-reform).

AssetValueTreatmentTaxable
Trading company shares£4,000,000First £1m: 100% BPR; remaining £3m: 50% BPR£1,500,000
Investment portfolio£3,000,000No relief£3,000,000
House£1,500,000RNRB partially applies (but estate >£2m so RNRB tapered)£1,500,000
Nil-rate band(£325,000)Standard NRB−£325,000
Taxable estate£5,675,000

IHT at 40% = £2,270,000. Pre-2026 (full 100% BPR on the company), it would have been roughly £1,070,000 — the reform doubles the bill.

Common BPR mistakes

Sources

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