Carlton has identified the potential for APR to be restricted.
When considering development of property which qualifies for APR, it is important to remember that APR only applies to the agricultural value of the land in question. If the land is valued at, say £2,000 an acre for agricultural purposes, but £100,000 an acre as development land, APR will be limited to a maximum of £2,000 an acre.
If there is likely to be a significant uplift in value with no corresponding uplift in available IHT reliefs, it might be appropriate to consider winding up the trust with the land passing to the remaindermen, thus trying to secure the maximum APR relief before initiating any development. However, this could be allowing the “tax tail” to “wag the dog”!