Reforms to Inheritance Tax agricultural property relief and business property relief: application in relation to trusts

Question 1

Summary

Accepted Answer

At Autumn Budget 2024, the government announced several reforms to agricultural property relief and business property relief from Inheritance Tax. In particular:

a new £1 million allowance will apply to the combined value of property that qualifies for 100% business property relief or 100% agricultural property relief or both – after the £1 million allowance has been exhausted, relief will apply at a lower rate of 50% to the combined value of qualifying agricultural and business property
the rate of business property relief available will be reduced from 100% to 50% in all circumstances for shares admitted to trading on a recognised stock exchange which are not ‘listed’

Scope of this consultation

This technical consultation seeks views on aspects of the application of the £1 million allowance for property settled into trust qualifying for 100% agricultural property relief or business property relief.

Who should read this

Individuals, personal representatives, settlors, trustees and other trust professionals, tax and legal practitioners.

Duration

The consultation will run for 8 weeks between 27 February 2025 and 23 April 2025.

Lead officials

The lead officials are the Assets, Residence and Valuation team of HM Revenue and Customs (HMRC).

How to respond or enquire about this consultation

You can respond by using the online form or by sending responses to aprbpr.consult@hmrc.gov.uk.

Responses should be sent by 23 April 2025.

After the consultation

The government will publish a response document and carry out a technical consultation on draft legislation for these changes later this year.

Question 2

Executive summary

Accepted Answer

At Autumn Budget 2024 the government announced changes to agricultural property relief and business property relief from Inheritance Tax from 6 April 2026.

These changes will have an impact on the Inheritance Tax payable by certain trusts comprising of property that qualifies for agricultural property relief or business property relief where the value of that property exceeds £1 million. The government is consulting on this aspect to ensure the rules work as intended.

Part 1 of this consultation sets out the relevant background on Inheritance Tax and trusts.

Part 2 explains how the changes announced at Autumn Budget 2024 will work for transfers made on or after 6 April 2026.

Part 3 seeks views on transitional provisions for transfers made before 6 April 2026.

Part 4 seeks views on the introduction of an anti-fragmentation rule for trust property settled on or after 30 October 2024.

Part 5 sets out how the announced changes will apply to special trusts, including Qualifying Interest in Possession (QIIP) trusts and beneficiaries of age 18 to 25 trusts.

Part 6 summarises the consultation questions.

Part 7 announces that, from 6 April 2026, the government will ensure the option to pay Inheritance Tax by equal annual instalments over 10 years, interest-free, is available to all property which is eligible for agricultural property relief or business property relief.

Part 8 sets out the process for responding.

Question 3

1.  Inheritance Tax and trusts: relevant background and current law

Accepted Answer

Inheritance Tax: nil-rate bands, exemptions and reliefs

Inheritance Tax is a tax on the estate (the property, money and possessions) of someone who has died. Inheritance Tax is paid on the value of the estate transferred at death, and on the value of any chargeable lifetime transfers of property (meaning gifts to individuals or transfers of property into trust) in the 7 years before death, above a threshold known as the nil-rate band. The nil-rate band is currently set at £325,000. There are several further thresholds and exemptions which may be available, including the residence nil-rate band and exemptions for property transferred to a spouse or civil partner.

Transfers of certain types of agricultural and business assets will be eligible for agricultural property relief or business property relief. These reliefs will reduce the value of the eligible property by the applicable rate of relief (either 100% or 50%, depending on the type of asset) before any exemptions or nil-rate bands are applied. If property being transferred qualifies for the 100% rate of agricultural property relief or business property relief, then its value is reduced to nil and no Inheritance Tax will be due on the transfer.

Lifetime transfers: potentially exempt transfers (PETs)

Most gifts a person makes during their lifetime, for example gifts to other individuals, will be exempt from Inheritance Tax if they survive for a further 7 years – these are known as potentially exempt transfers (PETs). If the person dies within 7 years of making the gift, Inheritance Tax may be due at up to 40% of the value of the gift (though this rate may be reduced by taper relief if the gift was made more than 3 years before death). This is known as a failed PET.

Lifetime transfers: property settled into relevant property trusts

Individuals may also transfer (or ‘settle’) property into a trust during their lifetime. This consultation document is primarily concerned with the Inheritance Tax treatment of property settled into relevant property trusts. Other types of trusts, including QIIP trusts, and Age 18 to 25 trusts for bereaved young people, are covered in Part 5 below.

A person who makes a lifetime transfer into a relevant property trust (a ‘settlor’) is subject to an immediate Inheritance Tax ‘entry charge’ at 20% of the gross value of that transfer, after any reliefs, exemptions and nil-rate bands have been applied. If the property being settled into trust is eligible for the 100% rate of agricultural property relief or business property relief, the value of the transfer is reduced to nil and the settlor will not be liable to pay any Inheritance Tax entry charge. The trustees of the settled property will then be subject to ongoing Inheritance Tax charges while the property is in the relevant property trust and when any property leaves the trust (further detail can be found in the next section on ongoing trust charges).

As with failed PETs, if the settlor dies within 7 years then Inheritance Tax will be due on the value of any transfers into trust during that period at up to 40% (with credit given for the 20% already paid in Inheritance Tax entry charges at the time when the property was settled into trust).

Relevant property trusts: ongoing trust charges

Property transferred into relevant property trusts is subject to ongoing Inheritance Tax charges, rather than being included in the value of a settlor or beneficiary’s estate on death. The main relevant property trust charges are an ‘anniversary charge’ at 10-year intervals and an ‘exit charge’ when property leaves the relevant property trust.

10-year anniversary charges: at each 10-year anniversary from the creation of a relevant property trust, there is a ‘principal’ charge of up to 6% of the value of the relevant property in the settlement – if property is added by the settlor after the creation or settled between 10-year anniversaries, an adjustment is made to tax those assets in proportion to how long they have been in the trust
exit charges: when there is a distribution or disposition of relevant property from the settlement, trustees will pay a proportion of 6% charge based on the length of time since the creation of the settlement or the last 10-year charge

If the settled property is fully eligible for the 100% rate of agricultural property relief or business property relief, then its value is reduced to nil and it will not be subject to any 10-year anniversary charges or exit charges.

Question 4

2.  Transfers made on or after 6 April 2026

Accepted Answer

Summary of reforms

The 100% rate of relief will continue for the first £1 million of combined agricultural and business property, with a 50% rate of relief thereafter. In practice, there will be 2 separate £1 million allowances for individuals and for trustees:

for individuals: a £1 million allowance on the combined value of agricultural or business property in an individual’s estate which qualifies for 100% relief, including property transferred on death, any PETs and chargeable lifetime transfers made in the 7 years before death and any immediately chargeable lifetime transfers, such as property settled into trust
for trustees: a £1 million allowance on the combined value of agricultural or business property settled into a relevant property trust which qualifies for the 100% rate of relief, to be applied on each 10-year anniversary charge and exit charge

The rate of relief will reduce from 100% to 50% in all circumstances for shares traded on but not listed on the markets of recognised stock exchanges (see HMRC’s list of designated recognised stock exchanges), such as AIM. The rate of relief will also reduce from 100% to 50% for qualifying shares listed on foreign exchanges which are not a recognised stock exchange.

The existing 100% rate of relief remains available for other unlisted shares such as shares in a private company.

These reforms do not affect the existing 50% rate of relief for certain types of business property or agricultural property (for example, quoted shares giving control of a company). The rate of relief for these assets will remain at 50% for any transfers on or after 6 April 2026.

The £1 million allowance will only be reduced by property that qualifies for 100% relief. Any property which qualifies for 50% relief will not contribute towards the allowance (see Case study 1 in Annex A).

Property which qualifies for the 100% rate of relief – and which therefore contributes to the £1 million allowance – is referred to throughout this document as ‘qualifying agricultural and business property’, to distinguish from property which qualifies for the 50% rate of relief.

Individual estates will continue to benefit from the nil-rate band, residence nil-rate band and other exemptions (including for transfers of property between spouses and civil partners) after the value of any available reliefs have been deducted.

£1 million allowance for individuals

The £1 million allowance for individuals will refresh every 7 years on a rolling basis in a similar way to how the nil rate band applies to lifetime charges and chargeable transfers on death.

Chargeable lifetime transfers, including property settled into trust

Any chargeable lifetime transfers made on or after 6 April 2026 – including any transfers into trust of qualifying agricultural and business property which give rise to an immediate 20% ‘entry charge’ on the settlor – will be subject to an individual’s £1 million allowance every 7 years (see Case study 2 in Annex A).

PETs

PETs made on or after 6 April 2026 will be subject to the £1 million allowance if the transferor dies within 7 years. Where there is a failed PET of qualifying agricultural or business property within 7 years of death, the Inheritance Tax due is calculated by cumulating the values transferred by chargeable transfers in the 7 years before the failed PET in the usual way. Chargeable transfers of qualifying agricultural and business property made within 7 years of a failed PET may reduce the £1 million allowance applicable on death depending on the date of death as illustrated at Case study 3 in Annex A.

Where a failed PET is also a gift with reservation ceasing on death, and relief applies to the earlier charge under the Inheritance Tax (Double Charges Relief) Regulations 1987 (SI1987/1130), the earlier transfer will not reduce the £1 million allowance available on death where the death charge results in a higher rate of tax.

Apportionment and allocation of the £1 million allowance for individuals

The £1 million allowance will apply across the whole estate, so where there is qualifying agricultural and business property in more than one component of the estate (for example, a QIIP trust (see section 5 Special trusts), or a gift with reservation ceasing on death), the £1 million allowance will be apportioned across all the qualifying property (see Case study 4 in Annex A).

Where the total combined value of qualifying agricultural and business property is more than £1 million, the £1 million allowance will be allocated on a chronological basis, starting with the earliest chargeable transfer to which these rules apply, including failed PETs (see Case study 5 in Annex A). This is consistent with how the nil rate band is allocated. When the £1 million allowance has been used up entirely by chargeable lifetime transfers, 50% relief will apply to subsequent chargeable lifetime transfers and any qualifying agricultural and business property included in the estate on death.

Any unused allowance is not transferable between spouses and civil partners. However the estate of the surviving spouse or civil partner will be entitled to their own £1 million allowance for qualifying agricultural and business property, in addition to the nil-rate bands and other exemptions (including for transfers of property between spouses and civil partners).

Question 1: Are the rules on the application of £1 million allowance for individuals sufficiently clear for transfers made on or after 6 April 2026? What are your views on this?

£1 million allowance for 10-year anniversary charges and exit charges

There will be a combined £1 million allowance for trustees on the value of qualifying agricultural and business property held in relevant property trusts. This allowance will apply when calculating the amount of relief available at each 10-year anniversary charge and on exit charges. Trusts with a combined value of more than £1 million of qualifying agricultural and business property will receive 100% relief against ongoing trust charges up to a value of £1 million, and 50% relief thereafter.

The £1 million allowance for relevant property trusts will refresh every 10 years, so that qualifying agricultural and business property held in that trust benefits from 100% relief up to a value of £1 million on each 10-year anniversary charge. This means that if the open market value of qualifying agricultural and business property held in a relevant property trust remains below £1 million (and assuming that there have been no exit charges between 10-year anniversaries), then the property will always be within the allowance at 10-year anniversaries.

The £1 million allowance will also apply to qualifying agricultural and business property which is subject to an exit charge. This means that 100% relief will be available on up to £1 million of qualifying agricultural or business property when it is distributed from a trust, irrespective of when this occurs within a 10-year period. If there are multiple exits during a 10-year period, then the relief is applied cumulatively. For example, if the first exit uses £250,000 of the £1 million allowance, then 100% relief can then be used against the next exit charge up to a value of £750,000, and so on until the next 10-year anniversary.

Any £1 million allowance which is used against an exit charge will reduce the maximum allowance that is available at the next 10-year anniversary. This ensures that the £1 million allowance applies across all trust charges, and prevents the allowance from being applied twice, once on exit and again at the following 10-year anniversary. In line with existing rules, there is no exit charge in the first quarter following the creation of the trust and a 10-year anniversary charge, so the £1 million allowance will not apply to such exits.

Question 2: Are the rules on the application of the £1 million allowance for 10-year anniversary charges and exit charges sufficiently clear for property settled on or after 6 April 2026? What are your views on this?

Standardisation of exit charges before and after the first 10-year anniversary charge

Currently, the rate of Inheritance Tax applied to an exit charge (up to a maximum of 6% of the value of the distribution) will vary depending on whether the distribution takes place before or after the first 10-year anniversary. Once the initial rate is established, the calculation is then reduced by a number of fortieths, to take into account the length of time in quarter years that the property has been in the trust since set-up or the last 10-year anniversary.

For exit charges before the first 10-year anniversary, agricultural property relief and business property relief is not taken into account when calculating the initial rate of Inheritance Tax. This means that the rate of Inheritance Tax applied to the property leaving the trust will be higher because it is based on unrelieved values. If the property leaving the trust qualifies for 100% relief, then no Inheritance Tax is payable. However, where all or part of the property subject to the exit charge does not qualify for 100% relief the tax payable will be subject to the higher rate.

Unlike exit charges before the first 10-year anniversary, agricultural property relief and business property relief is taken into account when calculating the rate of Inheritance Tax for exit charges between 10-year anniversaries. As such, the rate of Inheritance Tax is reduced by the value of relievable property. Again, if the property leaving the trust qualifies for 100% relief, no Inheritance Tax is payable on the transfer. However, where part or all of the property subject to the exit charge does not qualify for 100% relief the tax payable can still benefit from the lower rate of tax, which in some cases could be nil.

For distributions of all settled property made following a 10-year anniversary which arose on or after 6 April 2026, agricultural property relief and business property relief will not be taken into account when calculating the rate of Inheritance Tax. The rate of tax will therefore be based on unrelieved values instead of relieved values and remains a maximum of 6%.

This does not prevent the £1 million allowance being applied to distributions of qualifying relievable property. It simply ensures that the rate of tax on distributions of property is treated consistently for Inheritance Tax purposes, regardless of whether they fall before or after the first 10-year anniversary charge.

Question 3: What are your views on the proposal to standardise the calculation of Inheritance Tax exit charges, so that all exit charges are calculated based on unrelieved values regardless of whether the exit takes place before or after the first 10-year anniversary?

Question 5

3.  Transitional provision for trusts and transfers made before 6 April 2026

Accepted Answer

Transfers made before 30 October 2024

PETs and chargeable lifetime transfers

PETs and chargeable lifetime transfers that were made before 30 October 2024 will not be affected by the announced changes and will be subject to the rules in place at the time they were made. They will not be brought into cumulation for the purposes of determining the £1 million allowance available for chargeable transfers of qualifying property arising after that date.

Relevant property trusts: trust charges

Qualifying agricultural and business property settled into a relevant property trust before 30 October 2024 will be brought into the new regime on the trust’s next 10-year anniversary charge which falls on or after 6 April 2026.

Any qualifying agricultural or business property settled before 30 October 2024 which exits the trust will continue to attract unlimited 100% relief on Inheritance Tax exit charges until the date of the trust’s next 10-year anniversary which falls on or after 6 April 2026. Such exits will not reduce the £1 million allowance available at the next 10-year anniversary. Thereafter, the trustee’s £1 million allowance will apply to any exits of qualifying agricultural or business property from the settlement, in the same way as for qualifying property settled into trust on or after 6 April 2026.

When calculating the first 10-year anniversary charge after 6 April 2026, the £1 million allowance for trustees will only apply to complete quarters which fall on or after 6 April 2026 for qualifying property settled before 30 October 2024 (see Case study 6 in Annex A).

After that anniversary, the trustees’ £1 million allowance will apply in the same way as for qualifying agricultural and business property settled into trust on or after 6 April 2026.

Question 4: What are your views on the proposed transitional provisions for qualifying agricultural and business property settled into a relevant property trust before 30 October 2024?

Transfers made on or after 30 October 2024 and before 6 April 2026: ‘the transitional period’

At Autumn Budget 2024, the government announced that the £1 million allowance for individuals will apply to lifetime transfers made on or after 30 October 2024 if the donor dies on or after 6 April 2026.

The new 50% rate will also apply to any PETs or chargeable lifetime transfers of shares traded on but not listed on the markets of recognised stock exchanges, made during the transitional period and within 7 years of death where the death is on or after 6 April 2026. PETs or chargeable lifetime transfers of qualifying shares listed on foreign exchanges made during the transitional period will not be subject to the new 50% rate as the new rules do not apply to this category of shares until 6 April 2026.

PETs

The £1 million allowance for individuals will apply to any PETs of qualifying agricultural and business property made during the transitional period, where the transferor dies within 7 years of the transfer and on or after 6 April 2026 (see Case study 5 in Annex A).

If the transferor makes any PETs during the transitional period and dies before 6 April 2026, the new rules do not apply to the PETs or to any qualifying agricultural and business property in the estate on death and they will be subject to the rules which were in place at the time.

Chargeable lifetime transfers, including property settled into trust

The £1 million lifetime allowance for individual settlors will not apply to 20% entry charges on qualifying agricultural and business property settled into trust during the transitional period, provided that the settlor lives for 7 years after the transfer. Where the settlor survives the transfer by at least 7 years such a chargeable transfer will not be brought into cumulation for the purposes of determining the availability of the £1 million allowance for future chargeable transfers of qualifying property.

However, if the settlor dies on or after 6 April 2026 and within 7 years of making the transfer:

the value of any property transferred into trust during the 7 years before death will be subject to an Inheritance Tax charge at 40% in the same way as a failed PET
the settlor’s £1 million allowance will apply to these transfers of qualifying agricultural or business property and will reduce the allowance available on any later chargeable lifetime transfers or on death

Relevant property trusts: trust charges

The trustees’ £1 million allowance will not apply to exit charges for any qualifying agricultural or business property which has been settled into trust on or after 30 October 2024, and subsequently exits the settlement before 6 April 2026. Any such exits will receive 100% relief from exit charges and will not reduce the value of the trustee’s £1 million allowance at the next 10-year anniversary charge. For exits after 5 April 2026 the £1 million allowance will apply and the value of the trustee’s £1 million allowance at the next 10-year anniversary charge will be reduced accordingly.

When calculating the first 10-year anniversary charge after 6 April 2026 for qualifying agricultural property and business property settled into trust during the transitional period, the trustees’ £1 million allowance will only apply to complete quarters which fall on or after 6 April 2026.

Question 5: What are your views on the proposed transitional provisions for qualifying agricultural and business property settled into a relevant property trust during the transitional period?

Question 6

4.  Anti-fragmentation: property added to multiple trusts on or after 30 October 2024

Accepted Answer

At Autumn Budget 2024, the government announced that it intended to introduce rules to prevent individuals from reducing their overall Inheritance Tax liabilities by settling property into multiple trusts on or after 30 October 2024.

For example, in the absence of any rule to the contrary, qualifying relievable assets valued at £5 million could be settled into 5 trusts in equal £1 million shares before 6 April 2026, with no entry charges provided the settlor does not die within 7 years, and no 10-year anniversary or exit charges on the trust, as relief at the higher rate of 100% would apply to each trust up to the £1 million allowance (assuming the property in each trust stayed at or below a market value of £1 million).

There are 2 main incentives to settle property into multiple trusts to reduce the impact of the £1 million allowance for trustees:

multiple £1 million allowances: an individual could settle qualifying agricultural and business property into multiple trusts, each entitled to a separate £1 million allowance against 10-year anniversary and exit charges.
valuation advantages: the value of certain assets (notably shares) may be discounted if they are fragmented so that they no longer constitute a control or majority holding – this lower valuation feeds through to the calculation of ongoing IHT charges, so that the total Inheritance Tax due on 10-year anniversaries and exits may be significantly less than if the assets were held in a single settlement

Single £1 million allowance for multiple trusts by the same settlor

Where a settlor has transferred qualifying agricultural or business property into multiple settlements on or after 30 October 2024, there will be a single £1 million allowance for 100% relief against ongoing relevant property trust charges. This will be allocated in chronological order, with priority given to the first settlement, then each successive settlement in order until £1 million of qualifying property has been settled and the entire £1 million allowance for 100% relief has been allocated to the trustees. The allocation of the single £1 million allowance applicable to each trust will apply for the lifetime of the trust.

For example, if £1 million of qualifying agricultural or business property is added to the first in a series of trusts, 100% relief will apply against ongoing trust charges in relation to that trust and will refresh every 10 years. But as the full £1 million allowance has been used-up by the first trust, the rate of relief on any relievable property added to a second trust, or any subsequent trusts will be limited to 50%.

If qualifying agricultural or business property is transferred into 2 or more trusts on the same day, the £1 million allowance will be apportioned across the value of the qualifying relievable property in the same way as the nil rate band.

The allocation of the £1 million allowance is fixed at the outset. If a trust can no longer use its allocation of the allowance, for example, because there is a distribution of qualifying agricultural or business property from the trust, then the unused allowance cannot be used by related trusts by the same settlor.

The above rules will not apply to pre-existing trusts that contained qualifying agricultural or business property as at 29 October 2024. Such trusts will each benefit from the £1 million allowance from 6 April 2026 even if the settlor transfers further qualifying agricultural or business property to more than one of these trusts.

Question 6: What are your views on introducing a single £1 million allowance for 10-year anniversary charges and exit charges where a settlor has transferred property into multiple trusts on or after 30 October 2024?

The ability to fragment property into individual components to reduce the value could confer a more significant tax advantage for settlors than multiple £1 million allowances.

The valuation rules for related property allow certain types of property (including property held by a spouse or civil partner, in certain circumstances) to be connected with property in an individual’s estate. If valuing the related property together gives a higher value than the normal method of valuation for each individual component, the higher value is used for Inheritance Tax purposes. The related property rules apply to lifetime transfers and transfers on death, but do not currently apply to relevant property trust charges.

To ensure that the reliefs are applied fairly and consistently, the government is seeking views on extending the existing rules for valuing ‘related’ property (s.161 Inheritance Tax Act 1984) from 6 April 2026 so that qualifying agricultural or business property settled by the same settlor across multiple trusts can be connected for valuation purposes. If valuing property in the different settlements together gives a higher value than for each individual settlement, then the higher value will be used when calculating 10-year anniversary charges and exit charges.

Question 7: What are your views on introducing rules similar to the existing ‘related’ property provisions for Inheritance Tax, so that multiple holdings by the same settlor across multiple trusts can be connected for valuation purposes?

Question 7

5.  Special trusts

Accepted Answer

Special trusts do not contain relevant property, and so are not subject to the relevant property trust 10-year anniversary and exit charges. They are however subject to their own exit charges and the Inheritance Tax treatment of these trusts will be affected by the changes to the extent that the trustees will be subject to the £1 million allowance for exit charges from 6 April 2026. Unlike relevant property trusts, the £1 million allowance will not refresh every 10 years for these types of trust as they are not subject to 10-year anniversary charges. Examples of special trusts (or favoured trusts) are:

temporary charitable trusts
employee benefit trusts

Age 18 to 25 trusts for bereaved young people

These are trusts for bereaved young people following the death of a parent where the young beneficiaries will take their share of the trust assets no later than age 25. The trust assets do not form part of the beneficiaries’ estate (so are not subject to the 40% charge) for Inheritance Tax until they have reached the specified age. There is, however, an Inheritance Tax exit charge when the beneficiaries take their share of the trust assets, for which the rate cannot exceed 4.2%.

The nature of these trusts means that the application of the £1 million allowance on the exit charge could produce unfavourable outcomes for younger siblings if for example, the eldest child uses up most or all of the allowance when they come of age and take their share of the fund. To prevent this kind of adverse outcome, the £1 million allowance will refresh for each successive beneficiary. This means that each young person who benefits from an age 18 to 25 trust will receive their own £1 million allowance for 100% relief to be used against the Inheritance Tax exit charge when their share of the funds are distributed.

QIIP trusts

Most assets settled after 2006 are subject to the relevant property regime outlined above. However, many pre-2006 trusts, some Will Trusts and trusts for disabled persons after that date are QIIP trusts, which are taxed differently.

For Inheritance Tax purposes, the person who has a qualifying interest in the QIIP trust (such as the right to income from the trust or to live in a property) is treated as owning the underlying trust assets. These are then included in their estate on death rather than being subject to ongoing 10-year anniversary and exit trust charges. If the individual still has the interest at death (or if it is transferred within 7 years of death) the trust assets are taxed at up to 40%.

Any qualifying agricultural or business property which is held in a QIIP trust will continue to be included in the beneficiary’s individual estate on death. The £1 million allowance for individuals will apply to qualifying agricultural or business property held in a QIIP trust where the person with an interest dies on or after 6 April 2026.

If there has been a lifetime transfer of qualifying agricultural or business property from the QIIP trust on or after 30 October 2024, and the person with an interest subsequently dies on or after 6 April 2026, the £1 million allowance will apply to this transfer.

The £1 million allowance (or any allowance remaining after it has been applied to any failed PETs or chargeable lifetime transfers of qualifying agricultural or business property) for the person with an interest will be apportioned between the qualifying agricultural or business property in which they had an interest, and other such property in their estate at death (see Case study 4 in Annex A).

Question 8: What are your views on the application of the £1 million allowance to special trusts, age 18 to 25 trusts and QIIP trusts?

Question 9: Do you have any further views on the application of the £1 million allowance to property which has been settled into trust?

Question 8

6.  Summary of consultation questions

Accepted Answer