As changes to inheritance tax loom, farming families are being urged to start conversations now about succession and the future of their business. In his latest article for FT Adviser, Roman Kubiak explores how forthcoming reforms to inheritance and tax reliefs could have far-reaching implications for the agricultural community, and why open communication is vital to avoid costly family disputes.
Article summary
From 6 April 2026, significant reforms to inheritance tax (IHT) will take effect, capping agricultural property relief (APR) and business property relief (BPR) at £1 million per individual. Assets above this threshold will only receive 50% relief, effectively resulting in a 20% tax rate on the excess. While the new regime allows the tax to be paid over ten years interest-free, it raises pressing questions about how family farms will manage the financial burden.
In the article drafted for FT Adviser, Roman explains that these changes should serve as a starting point for proactive succession discussions. Cultural reluctance to talk about “death and taxes” has long contributed to disputes within farming families, often escalating to court when informal inheritance promises are broken. Drawing on his experience in the Davies v Davies (“Cowshed Cinderella”) case, Roman highlights how the absence of written agreements can leave potential heirs vulnerable.
The article sets out a five-step framework to guide families through constructive succession planning:
- Education – understand the tax reforms and their implications.
- Specifics – assess how they impact the business.
- Red lines – identify each party’s non-negotiables.
- Formalise – document agreements through wills or partnership arrangements.
- Review – revisit plans regularly as circumstances or laws change.
Legal context
The forthcoming inheritance tax cap, announced in the Autumn Budget 2024, will reshape how agricultural assets are passed on. The article also explores the principle of proprietary estoppel — a legal protection for individuals who have relied on promises of inheritance to their detriment — which often underpins disputes when succession plans are not formalised.
