Tax Update for Private Client Practitioners 2026

This talk will explore key planning considerations for Agricultural Property Relief (APR) and Business Property Relief (BPR), including the main structuring options for farms and businesses, common issues that arise when allocating reliefs in wills, and how discretionary trusts can be used as part of the planning approach in higher-value estates.

• Planning options for farms and businesses valued at up to £2.5m, and those exceeding this threshold
• Illustration of the three main options:
  • Leaving assets to the surviving spouse (either outright or via an IPDI trust)
  • Leaving assets directly to children
  • Leaving assets to children via a discretionary trust (D/T)
• Issues with will provisions referring to “my fully relievable property” and “my partially relievable property”, including:
  • The difficulty that the 100% allowance cannot be allocated to a specific gift if that is the ultimate outcome of the flexible beneficiary structure
  • The risk of relief being lost due to the “spread rule” in s.39A
• Planning using discretionary trusts, including the use of s.144 to ensure the appropriate amount remains in the discretionary trust, with the residue passing to an IPDI trust or outright to the surviving spouse
• Returning to discretionary trusts as a planning solution, but only as a starting point in higher-value estates

Simon Douglas, Barrister, 5 Stone Buildings

This talk will consider key issues in lifetime planning involving Agricultural Property Relief (APR) and Business Property Relief (BPR), focusing on how reliefs can be used effectively during lifetime transfers and the planning structures that may be appropriate for farms and trading businesses, including: 

• The value of gifting to a spouse so they can utilise the £2.5m allowance, and potentially more where 50% relief applies
• Ensuring the relief can effectively be “banked” on the first death in case of a later sale of the asset or loss of BPR (e.g. where the business ceases to be mainly trading) before the second death
• Lifetime succession planning and use of the £2.5m allowance – when it becomes renewable (noting Rose’s reply to Claire regarding the trust allowance)
• How the trust allowance will operate where gifts are made after 5 April 2026
• Asset protection considerations in lifetime gifting, and the value (and limits) of using trusts compared with alternatives such as pre-nuptial and post-nuptial agreements
• Structures to consider, including partnerships for farming businesses compared with trading company structures
• Any specific rural issues to be aware of in this context

Naomi Neville, Solicitor, Partner, Irwin Mitchell

This session will examine the evolving role of pensions in estate planning in light of the changes coming in April 2027, and how pensions will interact with other planning tools. In particular, it will cover:

• The role of pensions in a financial plan, given the changes due in April 2027.
• Illiquid assets in pensions – including commercial property and business assets – and the practical issues that arise.
• Annuities in the current environment.
• Life insurance within a modern estate planning framework.
• Other wealth planning strategies and tax-advantaged vehicles:
  • VCTs, EIS and Business Relief investments (including structures such as Octopus/Triple Point)
  • Investment bonds as an estate planning and tax-planning tool
  • Trust-based strategies such as loan trusts and discounted gift trusts

Ola Adeosun, Partner, Head of Regional Wealth Planning, LGT Wealth Management

This talk will examine key aspects of lifetime inheritance tax (IHT) planning involving property, highlighting the effective use of exemptions, common anti-avoidance rules, and practical issues that can arise when transferring or sharing property interests. This session will study:

• Effective use of IHT exemptions, including potential traps with the normal expenditure out of income exemption
• Key anti-avoidance rules: GWR, POAT, DOTAS and PCRT
• The s.102B(3) and (4) FA 1986 exemptions – giving away a property interest while retaining a rental arrangement
• Application of DOTAS to property planning, including gifts to a co-occupier and the full consideration exemption
• Sharing property with elderly relatives – issues and potential traps to consider
• BOMAD planning considerations – gift, loan, guarantee of a mortgage, or transfer of a share of equity
• Post-Budget 2025 considerations: planning ahead of the proposed “Mansion tax” in April 2028 and the additional 2% on dividends and savings income

John Bunker, Solicitor, Chartered Tax Adviser and Lecturer

Part 1

• What valuations of farm/rural business are needed for IHT, if assets held in own name, partnership or company structure?
• What info does a valuer need for such valuations?

Nicholas Watson, Head of Private Client, Strutt & Parker Part 2

• Why is the value in the company accounts not enough - what more is needed?
• What are the valuation rules regarding percentages of company shares?
• Where are the issues in negotiating discounts with SVD?

Adam Cooper, Partner, Valuations, Forvis Mazars

5.00pm Close of Proceedings