Agricultural and Business Property Relief

(Limited Text - Ministerial Extracts only)

Tuesday 14th January 2025 Westminster Hall

[The Exchequer Secretary to the Treasury (James Murray)]

It is a pleasure to speak in this debate with you as Chair, Dr Allin-Khan. I congratulate the right hon. Member for Beverley and Holderness (Graham Stuart) on securing this debate. Likewise, he is always thoughtful in his contributions, so I am always glad to hear from him and indeed the interventions that he allowed during his speech.

I know hon. Members have raised questions about the reforms that we are making, and I will try to address as many of them as I can. However, let me start by briefly reminding hon. Members of the economic context in which the decisions were taken. At the autumn Budget, we took difficult but necessary decisions on tax, welfare and spending

to restore economic stability, fix the public finances and support public services, as a result of the situation that we inherited from the previous Administration. We took those tough decisions in a way that will make the tax system fairer and more sustainable. The decision to reform agricultural property relief and business property relief was not taken lightly. The reforms mean that, despite the tough fiscal context, the Government will maintain significant levels of relief from inheritance tax, beyond what is available to others.

[Richard Foord (Honiton and Sidmouth) (LD)]

Will the Minister give way?

[James Murray]

I will give way maybe once or twice, but I do not have much time.

[Richard Foord]

I do not question the Minister’s difficult inheritance, but the Labour party adviser Dan Neidle suggests that the plan to slap inheritance tax on farms worth more than £1 million should be replaced with a much higher threshold with a clawback mechanism, perhaps for land over £20 million that is sold. That would tackle the Dysons of the world without affecting small family farms. What does the Minister think of that proposal?

[James Murray]

I am just about to come on to the details of the reforms that we have made to agricultural property relief and business property relief. If the hon. Gentleman waits a moment, he will see some of the reasoning behind the decisions that we took.

The Government recognise the role that the reliefs play, particularly in supporting farms and small businesses, and under our reforms that will continue. The case for reform is underlined by the fact that the full unlimited exemption, which was introduced in 1992, had become unsustainable. Under the current system, the benefit of the 100% relief on business and agricultural assets has become heavily skewed towards the wealthiest estates. According to the latest data from HMRC, 40% of agricultural property relief benefits the top 7% of estates making claims. That is 117 estates claiming £219 million of relief.

It is a similar picture for business property relief. More than 50% of business property relief is claimed by just 4% of estates making claims. That equates to 158 estates claiming £558 million in tax relief.

[Mr Angus MacDonald]

Will the Minister give way?

[James Murray]

I have only a few moments, so I will make progress.

The Leader of the Opposition has made it clear that she would prioritise that tax break within the public finances, but we do not believe it is fair or sustainable to maintain such a large tax break for such a small number of the wealthiest claimants, given the wider pressures on the public finances. It is for those reasons that the Government are changing how we target agricultural property relief and business property relief from April 2026. We are doing so in a way that maintains a significant tax relief for estates, including for small farms and businesses, while repairing the public finances fairly.

Let me be clear that individuals will still benefit from 100% relief for the first £1 million of combined business and agricultural assets. On top of that, as we know, there will be a 50% relief, which means that inheritance tax will be paid at a reduced effective rate of up to 20%, rather than the standard 40%. Importantly, those reliefs sit on top of the existing spousal exemptions and nil-rate bands. Depending on individual circumstances, a couple can pass on up to £3 million to their children or grandchildren free of inheritance tax.

[Harriet Cross]

At the Oxford farming conference, the Secretary of State suggested that farms should diversify to be more profitable, but diversification has become a lot less incentivised because that all gets wrapped up into the BPR, as well as the APR. Does that not completely negate the Secretary of State’s argument for diversification if it will all be taken away in tax?

[James Murray]

My right hon. Friend the Secretary of State made an important point about diversification, but whatever category the assets fall into, a couple can pass on up to £3 million to their children or grandchildren free of inheritance tax; that applies across agricultural and business property relief. The point I was making is that the agricultural and business property relief sit on top of the existing transfers and nil-rate bands, so when considering individual circumstances, we must look at the details of the situation that an individual or couple face.

I have a minute left, so I will be brief. Some hon. Members questioned the statistics about how many estates will be affected. We are very clear—we have published the data, and the Chancellor has written to the Treasury Committee about it—that up to 520 estates claiming agricultural property relief, including those claiming business property relief too, will be affected by these reforms to some degree. That means that about three quarters of estates claiming agricultural property relief, including those also claiming business property relief, will not pay any more tax as a result of these changes in the year they are introduced. All estates making claims through these reliefs will continue to receive generous support at a total cost of £1.1 billion to the Exchequer. The Office for Budget Responsibility has been clear that it does not expect this measure to have any significant macroeconomic impacts.

I thank all hon. Members who have contributed today, and I am grateful to the right hon. Member for Beverley and Holderness for securing this debate.

Motion lapsed (Standing Order No. 10(6)).