BPR/APR on lifetime gifts after April 2026

I thought this issue had been discussed before but I can’t find the thread re a quirk in the new rules on CLTs.

The new rules wording discussed in the Government document Reforms to Inheritance Tax agricultural property relief and business property relief: application in relation to trusts - GOV.UK suggests that when looking at a chargeable transfer after April 2026 a BPR/APR asset is 50% relief unless within the £1m allowance.

However, the example in the document shows the 50% relief against the full IHT rate of 40% rather than against the lifetime chargeable rate of 20%. So the effect is that chargeable lifetime gifts over £1m after April 2026 even if qualifying BPR/APR property the IHT rate is 20% the same as non BPR/APR assets i.e. there is effectively no 50% relief. Do others agree this is as intended as I can’t quite square this within the draft legislation.

I’m looking at how this might affect CLT’s where the settlor doesn’t survive 7 years. The draft legislation suggests that CLT’s falling taxable on the death estate essentially end up with the same calculation with the amount over £1m being 50% of the 40% - so 20% chargeable. In effect, no further tax would be due on death.

Is my understanding correct or do we think the example in the document is an anomaly?

If you mean Case Study 2, I think that is correct. The relief is applied by reducing the transfer of value down from £2m to £500,000 (£1m at 100% and £1m at 50%). The usual 20% rate is then applied to this reduced transfer of value.

Or maybe I have misunderstood your question.

Thank you Andrew. I was being a complete ninny - the effective rate is of course 10% in the example I completely misread it.