APR and BPR assets are generally highly illiquid unless a sale is round the corner. Will this marginal rate of 20% IHT over £1m force sales to pay tax and destroy succession within the family? Borrowing to pay tax at current rates is most unattractive. There should have been a deferral relief as for woodlands or conditional exemption as for heritage assets.
Expect more proprietary estoppel claims. Sons and daughters claiming dad gave away the farm over 7 years ago when he made the actionable promise.
“The new rules will apply for lifetime transfers on or after 30 October 2024 if the donor dies on or after 6 April 2026. This prevents forestalling. For example, a lifetime gift of unquoted shares of £2 million made on or after 30 October 2024 will be a failed potentially exempt transfer if the donor dies within 7 years.”
If there are any elderly farmers holding on to land, now would be a good time to make gifts and potentially shuffle off in the next 18 months.