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Trusts & Estates

Inheritance Tax reforms: What you need to know

Major changes to the UK’s inheritance tax (IHT) regime were announced in the 2024 Autumn Budget, with further reforms expected in the years ahead. For individuals and families thinking about how and when to pass on wealth — particularly those with business interests, agricultural property or large pension savings — this is a timely moment to revisit succession planning.

At the same time, a global shift in wealth is accelerating. With over $84 trillion expected to change hands by 2045, inheritance planning has evolved beyond mere tax considerations to include aspects such as timing, legacy, and impact. It’s also about timing, legacy and impact.

How IHT works today

IHT is usually charged at 40% on the value of an estate above the nil-rate band of £325,000, potentially rising to £650,000 for married couples or civil partners.

Some lifetime gifts may fall outside the taxable estate, provided the donor survives for seven years. Other exemptions and reliefs may apply, including:

  • Transfers between spouses or civil partners
  • An additional £175,000 exemption when passing down the main residence
  • Gifts from surplus income
  • Life event gifts, such as for marriage
  • Charitable bequests, which may reduce the overall IHT rate to 36%
  • Reliefs for certain business or agricultural assets

Business Property Relief (BPR) and Agricultural Property Relief (APR) are now facing significant reform.

Inheritance planning has evolved beyond mere tax considerations to include aspects such as timing, legacy, and impact.

What’s changing? A closer look at BPR, APR and pensions

The most notable change is the introduction of a £1 million cap on property qualifying for 100% relief under BPR and APR. Any value above this cap will attract only 50% relief, reducing the protection once afforded to high-value farms and family businesses.

Assets that have historically received 50% relief are excluded from the new allowance. In all cases, qualifying assets must be held for at least two years prior to transfer.

These rules apply to transfers made after 30 October 2024, where the donor dies on or after 6 April 2026. Transfers made before the deadline are not affected, even if the donor dies within seven years.

Discretionary trusts are also affected. Trusts holding qualifying property may now face IHT charges on each ten-year anniversary or upon distribution. Where a trust contains only qualifying assets, the charge is expected to be around 3% of the net value. These trusts should each be afforded their own £1 million allowance, although where qualify property is transferred into more than one trust on or after 30 October 2024, the £1 million allowance is expected to be shared between those trusts.

From 6 April 2027, most unused pension funds and death benefits will also be included in an individual’s estate for IHT purposes. Executors will be responsible for reporting the pension value and payment, beneficiaries may face income tax on received benefits. This will make inherited pensions less tax-efficient than in the past.

A £1 million cap on key reliefs marks a fundamental shift in how wealth is passed on in the UK.

Planning ahead: What to consider

These changes could impact many families, particularly those with business assets, agricultural property, complex trusts or large pensions. While the effects may not be immediate, proactive planning can help protect your position.

There is still time to make use of the current rules. For some, this could mean bringing forward plans to transfer business or agricultural assets. (Gifts that have been made before 30 October 2024 will not be subject to the new £1 million cap, regardless of whether the donor survives the gift by seven years).

Life insurance may offer another route. A policy written in trust can give beneficiaries a tax-free sum to cover future liabilities. For those with BPR or APR-qualifying assets, the required cover may be modest.

With time still available, careful planning can preserve flexibility and protect your legacy.

Rebalancing your asset base may also be worth exploring. Reducing reliance on property or business holdings — and maintaining liquidity — could help manage future IHT exposure.

Pension strategy should be re-evaluated too. Drawing the 25% tax-free lump sum during your lifetime may now be more attractive, allowing you to gift funds or meet personal expenses while reducing your estate’s value.

Finally, those considering charitable giving may benefit from acting sooner. Lifetime donations can deliver both income tax benefits and IHT relief, and may be more efficient than posthumous bequests.

FAQs

Will the new £1 million limit apply to my existing business or agricultural property?
Yes, if the assets are transferred after 30 October 2024 and the donor dies on or after 6 April 2026. Transfers made before that date are unaffected.

What about trusts?
Discretionary trusts settled before the deadline should each benefit from their own £1 million cap. However, they may still be subject to periodic IHT charges of around 3% where the thrust contains only qualifying BPR assets.

Are all pensions affected?
Most unused pensions will fall within the IHT net from 6 April 2027. Tax treatment depends on the scheme and how benefits are distributed.


Can I still make gifts to individuals free of inheritance tax?
Yes. The gift should not give rise to inheritance tax on death provided the donor survives the gift by seven years.  

Should I update my succession plan?
If you hold business, agricultural or pension assets, or make use of trusts, it’s advisable to review your arrangements now.

In summary

The UK’s inheritance tax system is undergoing fundamental change. The tightening of BPR and APR, along with the inclusion of pensions, will alter how wealth is passed on.

However, with time still available, careful planning can preserve flexibility and protect your legacy. Whether through gifting, restructuring or rethinking pensions and trusts, the steps you take now could make a lasting difference.

To explore what this means for you, speak with your J.P. Morgan team. Our Wealth Advisory specialists are on hand to support the conversation.

Please note that J.P. Morgan does not offer tax or legal advice. You should consult your own professional advisers to assess your personal position.

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At the same time, a global shift in wealth is accelerating. With over $84 trillion expected to change hands by 2045, inheritance planning has evolved beyond mere tax considerations to include aspects such as timing, legacy, and impact. It’s also about timing, legacy and impact.

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