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Agriculture | Talk Farm | S2 E4 | IHT briefing - what's next?
In this episode, James Frankland, Partner in our Agriculture and Estates team, sits down with Lisa Millington, Head of Agricultural Private Client, to give you the latest update on the rollercoaster that has been Inheritance Tax reforms for farmers and rural business owners.
James and Lisa begin with the Autumn 2025 budget, unpacking how Rachel Reeves’ announcement lived up to the hopes and fears of the farming community, and in particular the announcement that the relief allowance would be transferrable between spouses after all.
They then move on to the pre-Christmas U-turn, which saw the shock announcement that the £1 million Agricultural and Business Property Relief allowance would be uplifted from £1 million to £2.5 million, creating a potential £5 million relief for married couples.
— a shift that opened up meaningful estate planning opportunities, particularly for younger farming families looking ahead to future lifetime gifts. They explain how HMRC’s emphasis on “unused” relief interacts with existing spousal exemptions, and what that means in practice.
- Why the change represents a huge improvement — but not a complete solution
- How the U-turn may have been influenced by the Farm Profitability Review
- The types of farming businesses that benefit most (and those still left exposed)
- Real‑world examples of how clients’ inheritance tax positions are shifting
- Why this is about supporting businesses as well as farms
Looking ahead, James and Lisa outline the steps farmers can still take before the rules come into force in April, reflect on rumours of possible delays, and clarify whether existing planning is now redundant (spoiler: it isn’t). They share practical actions — from reviewing structures to considering trusts — and discuss what we may expect from HMRC as implementation unfolds.
Talk Farm highlights the challenges and opportunities shaping rural life in the UK. Each episode offers expert industry commentary and practical guidance for those navigating the issues facing agriculture and landed estates today.
Listen wherever you get your podcasts, including Spotify and Apple Podcasts.
Find out more about HCR Law's services for Agriculture and Estates here.
View all episodes
By HCR LawIn this episode, James Frankland, Partner in our Agriculture and Estates team, sits down with Lisa Millington, Head of Agricultural Private Client, to give you the latest update on the rollercoaster that has been Inheritance Tax reforms for farmers and rural business owners.
James and Lisa begin with the Autumn 2025 budget, unpacking how Rachel Reeves’ announcement lived up to the hopes and fears of the farming community, and in particular the announcement that the relief allowance would be transferrable between spouses after all.
They then move on to the pre-Christmas U-turn, which saw the shock announcement that the £1 million Agricultural and Business Property Relief allowance would be uplifted from £1 million to £2.5 million, creating a potential £5 million relief for married couples.
— a shift that opened up meaningful estate planning opportunities, particularly for younger farming families looking ahead to future lifetime gifts. They explain how HMRC’s emphasis on “unused” relief interacts with existing spousal exemptions, and what that means in practice.
- Why the change represents a huge improvement — but not a complete solution
- How the U-turn may have been influenced by the Farm Profitability Review
- The types of farming businesses that benefit most (and those still left exposed)
- Real‑world examples of how clients’ inheritance tax positions are shifting
- Why this is about supporting businesses as well as farms
Looking ahead, James and Lisa outline the steps farmers can still take before the rules come into force in April, reflect on rumours of possible delays, and clarify whether existing planning is now redundant (spoiler: it isn’t). They share practical actions — from reviewing structures to considering trusts — and discuss what we may expect from HMRC as implementation unfolds.
Talk Farm highlights the challenges and opportunities shaping rural life in the UK. Each episode offers expert industry commentary and practical guidance for those navigating the issues facing agriculture and landed estates today.
Listen wherever you get your podcasts, including Spotify and Apple Podcasts.
Find out more about HCR Law's services for Agriculture and Estates here.