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Succession and family

The £2.5m Business Relief allowance: what it means for owners of trading groups

From April 2026 Business Relief is 100% on the first £2.5m and 50% above. Worked examples for owners of trading groups, plus excepted assets and planning.

By Omar Aswat CTA ·

Until 5 April 2026, shares in an unquoted trading company or the holding company of a trading group usually qualified for 100% Business Relief for inheritance tax, with no upper limit. A business worth £20m could pass to the next generation free of inheritance tax.

That changed on 6 April 2026. Business Relief (and agricultural property relief) is now:

  • 100% on the first £2.5m of combined qualifying business and agricultural property per person; and
  • 50% on the value above £2.5m.

The allowance was originally announced as £1m and raised to £2.5m on 23 December 2025. It's legislated in the Finance Act 2026 (s65 and Sch 12). Older guidance still shows £1m; that figure is out of date.

The new rules in brief

FeatureThe rule from 6 April 2026
Allowance£2.5m per person, at 100% relief
Above the allowance50% relief, so an effective 20% inheritance tax rate
What it coversCombined value of agricultural and business property
Spouses and civil partnersUnused allowance transferable to the survivor
TrustsA £2.5m allowance for relievable property in trusts
Lifetime giftsNew rules apply to gifts on or after 30 October 2024 where the donor dies on or after 6 April 2026 within 7 years
Paying the tax10 annual interest-free instalments for all APR/BPR property
IndexationIn line with CPI from 6 April 2031

Holding company shares still qualify in the same way

None of the qualifying rules changed. Shares in a holding company qualify where its business is wholly or mainly being the holding company of companies that trade (IHTA s105(4)(b)). You must have owned them for two years (s106), and if they came from a share-for-share exchange, the period you owned the original trading company shares counts (s107(4)).

What changed is how much relief you get once you qualify.

Worked examples

These are illustrations, not client examples. In each, the shares are in a holding company (HoldCo) of a trading group, all conditions are met, and the nil-rate band is assumed to be used by other assets.

Example 1: a single owner with shares worth £8m

StepAmount
Value of HoldCo shares£8,000,000
First £2,500,000 at 100% relief£0 taxable
Remaining £5,500,000 at 50% relief£2,750,000 taxable
Inheritance tax at 40%£1,100,000

Before April 2026, the same shares would have attracted no inheritance tax.

Example 2: a married couple with the same £8m

If the shares are held equally (£4m each) and each leaves their shares to the children:

Each spouseBoth
Value£4,000,000£8,000,000
At 100%£2,500,000£5,000,000
Above the allowance, 50% taxable£750,000£1,500,000
Inheritance tax at 40%£300,000£600,000

If instead the first spouse leaves everything to the survivor, that transfer is normally exempt, and the unused allowance passes across. The survivor then has £5m of allowance against the £8m. The total tax is the same £600,000, but it's paid on the second death.

Either way, the couple saves £500,000 compared with Example 1. Making sure both allowances are available, through ownership or wills, is now one of the simplest pieces of planning.

Example 3: the cost of surplus cash

Return to the single owner, but suppose £1m of HoldCo's £8m value is surplus cash that hasn't been used in the business for two years and isn't required for future use. That cash is an excepted asset (IHTA s112): it gets no relief.

StepAmount
Excepted cash, no relief£1,000,000 taxable
Qualifying value£7,000,000
First £2,500,000 at 100%£0
Remaining £4,500,000 at 50%£2,250,000 taxable
Total taxable£3,250,000
Inheritance tax at 40%£1,300,000

That's £200,000 more than Example 1, for the same total value. Excepted assets are now taxed at 40% while qualifying value above the allowance is taxed at an effective 20%, so surplus cash is doubly expensive. See how much cash is too much.

What this means for owners of trading groups

Check the value. Many owners have never had their shares valued because 100% relief made it irrelevant. Above £2.5m per person, value now drives the tax.

Use both spouses' allowances. Wills that leave shares in a way that wastes an allowance, or ownership that leaves one spouse with far more than £2.5m and the other with nothing, deserve a review. Transfers between spouses can be part of the answer.

Keep trading status clean. The trading test for Business Relief is "wholly or mainly", so a group with some surplus cash usually still qualifies, but excepted assets lose relief entirely. Earmarking cash for genuine business use, or moving it out of the group, matters more now.

Mind property and investment companies in the group. Where a group company's business is investment, HoldCo's shares are normally valued as if that company weren't in the group (IHTA s111). Premises occupied by the group's trading companies are an exception. See a property company in a group.

Think about lifetime gifts. A gift of HoldCo shares that you survive by seven years falls outside inheritance tax. Capital gains tax on a gift of shares in a trading group can usually be held over. For gifts on or after 30 October 2024, if you die within seven years after 5 April 2026, the new rules and your £2.5m allowance apply to the gift.

Watch sale contracts and buy-sell agreements. Shares under a binding contract for sale at the time of the transfer don't qualify (IHTA s113). Shareholders' agreements that oblige the survivors to buy a deceased shareholder's shares should be checked with this in mind.

Consider a structure above the group. Some families now look at a family investment company or trust above HoldCo, so that future growth sits with the next generation. These need careful design, and Business Relief, gift and trust rules all interact. See a family investment company above a group.

Plan for the tax, not just around it. With ten-year interest-free instalments now available for all business property, and exempt dividends able to move cash up to HoldCo, some families will simply plan to pay a 20% charge over time. That's a legitimate choice, but it needs liquidity in the right place.

The bigger picture

For a trading group worth up to £2.5m per person, or £5m for a couple, little has changed in practice. Above that, inheritance tax on business shares is back on the agenda, at an effective 20%. A holding company doesn't change the relief rules, but it gives you more ways to manage value, cash and ownership.

For more, see inheritance tax and holding companies. If you'd like to talk through your own position, book a call. We respond the same working day.

This article is general information, not advice. Tax rules change and their effect depends on your circumstances. Please speak to us before acting.

Parentsvoting shares: controlChildrengrowth shares: future valueFamily companyFIC, owns the holding companyTrustan alternative100%HoldCo Ltd100%TradeCo Ltddividends up
A family company above the group. A family investment company (or a trust) can sit above the holding company. The parents keep control through voting shares, while the children hold shares that take future growth. It moves value to the next generation gradually and under the parents' control. The inheritance tax, capital gains tax and settlements rules all need careful design. Holding company Trading company Investment company

FAQs

Frequently asked questions

How much inheritance tax is due on business shares worth more than £2.5m from April 2026?

On qualifying business property above the £2.5m allowance, Business Relief is 50%, so half the excess value is taxable at the 40% inheritance tax rate. That works out at an effective rate of 20% on the value above £2.5m, assuming the nil-rate band is used elsewhere. For example, holding company shares worth £8m that fully qualify would leave £5.5m above the allowance, of which £2.75m is taxable, giving inheritance tax of £1.1m.

If my spouse dies first and leaves everything to me, can I use their £2.5m allowance too?

Yes. From 6 April 2026, any unused part of the £2.5m allowance can be transferred to a surviving spouse or civil partner. Where the first death was before 6 April 2026, the whole £2.5m is assumed to be available to transfer. So a married couple can, in effect, shelter up to £5m of qualifying business and agricultural property at 100% between them, either by each owning shares or by the survivor using the transferred allowance.

Does the £2.5m allowance cover agricultural and business property separately?

No. The £2.5m is a single allowance covering the combined value of property qualifying for agricultural property relief and business property relief. If you own farmland and shares in a trading group, both draw on the same £2.5m. Qualifying property above that amount gets relief at 50%. The allowance is due to be increased in line with the consumer prices index from 6 April 2031, so it is fixed in cash terms until then.

I gave my children shares in the holding company in 2025. Does the new allowance apply?

It can. The new rules apply to lifetime gifts made on or after 30 October 2024 where the donor dies on or after 6 April 2026 and within seven years of the gift. If you survive seven years, the gift falls out of account for inheritance tax in the usual way. If you don't, the relief on the gift is worked out under the new rules, using your £2.5m allowance. Gifts before 30 October 2024 are not affected in this way.

Can inheritance tax on business shares be paid in instalments?

Yes. The option to pay inheritance tax by equal annual instalments over ten years, interest-free, has been extended to all property that is eligible for agricultural property relief or business property relief. That helps families who would otherwise need to sell shares or extract cash from the group to pay the tax quickly. The tax still has to be paid in full over that period, so instalments are a cash-flow tool rather than a saving, and the family needs a plan for funding each payment.

Why is surplus cash in a trading group more costly for inheritance tax since April 2026?

Because of the gap between the two rates. Cash or investments that have not been used wholly or mainly for the business throughout the last two years, and are not required for future use, are excepted assets. Their value is excluded from Business Relief and is taxed at the full 40% rate. Since April 2026, that matters more: qualifying value above £2.5m is effectively taxed at 20%, while excepted assets are taxed at 40%, so surplus cash in a trading group is particularly expensive.

Do shares in a trust get their own £2.5m Business Relief allowance?

Trusts have a £2.5m allowance of their own for the combined value of relievable agricultural and business property they hold. For trusts set up before 30 October 2024, the new rules take effect from the trust's next ten-year anniversary on or after 6 April 2026. The rules for trusts created later, and how the allowance is shared where one person sets up several trusts, are detailed, so take advice before settling shares in a trading group on trust.

Does the £2.5m cap make lifetime gifts of holding company shares more attractive?

For some owners, yes, but there is no single answer. A lifetime gift that you survive by seven years falls outside inheritance tax entirely, and capital gains tax on gifts of shares in a trading group can usually be held over. But you give up the shares and their income, and a gift with strings attached may not work. Keeping shares until death keeps control and income with you, and the £2.5m allowance applies then. The family's needs, your age and health, and who will run the business usually decide.

Talk to us before you buy, sell or restructure.

The right group structure protects what you've built and keeps your options open. A free first call with a Chartered Tax Adviser, and a reply the same working day.

Or write to taxadvisory@aswatax.co.uk

Chartered Tax Adviser
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