Business Relief after 6 April 2026: what changed and what to check

On 6 April 2026 the reformed Business Relief and Agricultural Relief rules came into force. As enacted, 100% relief now applies to the first £2.5 million of combined qualifying business and agricultural assets, with relief at 50% on the value above.

Why Wills drafted before the reform need checking

Many business owners' Wills contain clauses built on the old assumption of unlimited 100% relief - structures that made sense when the relief had no limit. Under the new rules, those same clauses can waste the availability of spousal exemption. The words have not changed; the law underneath them has. The difference a single correct clause makes, in the worked example we use in adviser training, is £108,000 of inheritance tax.

Our standard approach is to direct the first £2.5 million of qualifying business and agricultural assets into a Will Discretionary Trust, so the 100% relief is captured in full on first death rather than relying on it being available (or fully used) on second death. Any value above £2.5 million passes into an interest in possession trust for the surviving spouse, so that spousal exemption applies to that part. This mirrors the way we have long used discretionary trusts to capture the nil-rate band.

What the difference is worth

In our adviser training we work through a real-shape example: a business owner, Mr Smith, whose Will lacked the right clause. With a single addition, his estate saves £108,000 in inheritance tax and his children receive 9% more. Below the £2.5 million threshold the planning is straightforward; above it, the structuring becomes more involved - and getting the clause right becomes even more important, since it is the only way to make sure the maximum relief is actually captured rather than lost.

What to do

If you own business or agricultural assets and your Will predates April 2026, have it reviewed. The check is quick, and the cost of not making it can be measured in tens of thousands.

Key takeaways

• 100% relief now capped at £2.5m of combined qualifying assets; 50% on the value above
• The first £2.5m should be directed into a Will Discretionary Trust to capture the relief in full on first death
• Any value above £2.5m can pass into an interest in possession trust for the surviving spouse, using spousal exemption on that part
• Pre-2026 Wills with relievable-property clauses need review

(We do not give regulated tax advice: our role is designing the legal structures with the tax consequences in mind, working alongside your accountant or tax adviser on the detail.) Book a complimentary Will review with a STEP-qualified estate planner.