Inheritance Tax: Family-owned Businesses

James Murray Excerpts

Tuesday 3rd June 2025 Westminster Hall

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

It is a pleasure, Sir John, to speak in this debate with you as Chair, and I congratulate the hon. Member for Mid Dunbartonshire (Susan Murray) on securing it—I notice that the debate is being opened and closed by a Murray.

I know that some Members are very concerned about the impact of forthcoming reforms to inheritance tax reliefs on businesses in their constituencies, and I understand that people feel very strongly about inheritance tax. I should be clear that the Government believe that our reforms to business property relief and agricultural property relief get the balance right between supporting farms and businesses and fixing the public finances in a fair way. The reforms reduce the inheritance tax advantages available to owners of agricultural and business assets, but still mean that those assets will be taxed at a much lower effective rate than most other assets.

Let me make clear that, much like the hon. Lady set out, the Government recognise and greatly value the huge contribution that small and family-owned businesses make to their communities and the economy. Businesses large and small, including family businesses, will create jobs and wealth and be the engines of growth in the economy. Those businesses and their workforces are the backbone of our economy, and they are fundamental to kickstarting economic growth, which is the Government’s No. 1 mission. Those businesses need a Government who will take the right decisions in the national interest, including when they are difficult, to support our security and prosperity.

People who own, run and work in businesses of all sizes will remember the economic context that we inherited last year. They know how important responsible financial management is within their own businesses and how the success of businesses and their workforces depends on economic stability and public services that function well. I believe that many of them will understand that, since taking office, the Government have taken a number of difficult but necessary decisions on tax, welfare and spending to restore economic stability, fix the public finances and support public services. None of these decisions, including the decision to reform agricultural property relief and business property relief, was taken lightly, but those tough decisions were left to us by the previous Administration, and no responsible Government could have let things carry on as they were.

Alongside our work to stabilise the economy and restore discipline to the public finances, the Government are determined to do everything we can to support businesses to grow. We are overhauling the UK’s regulatory system to reduce burdens on businesses by 25% by the end of this Parliament. We have secured trade deals that will slash the cost of doing business abroad, reduce border checks, cut tariffs and axe red tape. Those trade deals will support jobs and create opportunities for Great British businesses in our biggest current markets and in one of the world’s biggest future markets, too.

The Government expect to publish an SME strategy later this year. It will set out the Government’s vision for SMEs, from encouraging entrepreneurship to boosting scale-ups across key policy areas, such as creating thriving high streets, making it easier to access finance, opening up overseas and domestic markets, building business capabilities and providing a strong business environment.

Despite the tough fiscal inheritance at the election last year, we have also taken decisions to continue supporting small businesses through the tax system. We have chosen to increase the employment allowance to £10,500 to take many small businesses out of paying national insurance contributions altogether. We froze the small business rates multiplier to protect small properties from inflationary bill increases, and we will introduce permanently lower business tax rates for small retail, hospitality and leisure businesses from 2026.

[Anna Gelderd (South East Cornwall) (Lab)]

In rural and coastal communities such as South East Cornwall, family-run businesses and farms are the backbone of the local economy. Does the Minister agree that any changes to inheritance tax must be carefully shaped to support our local businesses and farms to plan for their future so that they can pass on their hard-earned success?

[James Murray]

My hon. Friend is a great champion of businesses and farmers in her constituency. When we were deciding how to reform agricultural property relief and business property relief, we made sure that generous tax reliefs still existed in the tax system precisely because we want to continue to support small and family-owned farms and businesses in particular. I will come to those in a moment.

I am conscious that you asked me to give you a few moments at the end, Sir John. Do you mean at the end of my remarks?

[Sir John Hayes (in the Chair)]

I need about 15 seconds at the very end of your remarks.

[James Murray]

Got it. To conclude my remarks on the wider support that we are giving to businesses, I also draw hon. Members’ attention to the fact that we committed in the “Corporate Tax Roadmap”, which was published at the autumn Budget, to maintain the small profits rates and marginal relief at their current rates and thresholds, as well as the £1 million annual investment allowance.

I know that many Members are concerned about the reforms to inheritance tax that are the subject of the debate, so I will now turn to them. The reality is that the full, unlimited relief introduced in 1992 has become unfair and unsustainable, particularly in the economic context that we inherited. Under the current system, the 100% relief on business and agricultural assets is heavily skewed towards the wealthiest estates, which is clear from the latest HMRC data from 2021-22. More than 50% of business property relief was claimed by just 4% of estates making claims. That means that the wealthiest few per cent of estates claimed £558 million in tax relief. That contributes to the very largest estates paying a lower average effective inheritance tax rate than smaller estates. It is neither fair nor sustainable to maintain such a large tax break for such a small number of claimants, given the wider pressures on the public finances. It is for that reason that the Government are changing how we target agricultural property relief and business property relief.

Under the reformed system, estates will still benefit from 100% relief for the first £1 million of combined assets from April 2026, and on top of that there will be an uncapped 50% relief on further assets. That means that inheritance tax will be paid at a reduced effective rate of up to 20%, rather than the standard 40%. Those reliefs sit on top of the standard nil-rate bands and other exemptions, such as transfers between spouses and civil partners.

[Susan Murray]

Why do the Government not consider taxing large digital multinational corporations trading in this country in order to raise the extra revenue that is being raised from this measure, which effectively punishes the businesses that run the supply chains that export to those markets? Those businesses have relationships with specialist suppliers and are being put at risk.

--- Later in debate ---

[James Murray]

I believe that the hon. Lady is asking about the taxation of large multinational firms operating in the digital space. I am sure that she is aware of the digital services tax, which is currently in operation. The Government are committed to maintaining that until the pillar 1 international solution is implemented, and I am sure that she is familiar with pillar 2 of the OECD deal on a global minimum corporate tax rate. Large multinational firms are well dealt with on the international level, which is why, in opposition and in government, we have supported the OECD’s two-pillar solution.

I do not want to be distracted from the design of the reforms that we are talking about today. Where inheritance tax is due, those liable for a charge can pay any liability on the relevant assets over 10 annual interest-free instalments. That benefit is not seen anywhere else in the inheritance tax system.

There has been a lot of discussion of the impact of this policy, so let me set out the numbers, based on HMRC claims data. It is expected that, under these reforms, about 1,500 estates claiming only business property relief will pay more inheritance tax in 2026-27. Two thirds of those estates—about 1,000—are expected to only hold shares designated as not listed on the markets of recognised stock exchanges, such as the alternative investment market. Under these reforms, about three quarters of estates claiming business property relief in 2026-27, excluding estates only holding shares designated as not listed, will not pay any more inheritance tax in 2026-27.

The reforms to relief have generated a lot of commentary about the wider impacts, but hon. Members should take care when relying on analysis based on self-selecting surveys from members of representative groups campaigning against the reforms. Indeed, the independent Office for Budget Responsibility is clear that it does not expect this measure to have any significant macroeconomic impacts, and it certified the costing at autumn Budget 2024. It said that the reforms to agricultural property relief and business property relief are forecast to raise a combined £520 million in 2029-30.

[Richard Baker (Glenrothes and Mid Fife) (Lab)]

I recognise the need for the Government to raise funds, given the economic context that they inherited, but, as my hon. Friend the Member for Dunfermline and Dollar (Graeme Downie) said, a number of family businesses have come forward with alternative proposals that would raise the funds in a different way. Would the Minister and his team be prepared to meet and consult with family businesses to ensure that they have input into the plans? That would enable those businesses to inform them of their experiences and raise alternative proposals that might raise funds differently.

[James Murray]

I reassure my hon. Friend that I, and the wider team of officials, have had a number of meetings with representatives of family businesses and the agricultural and farming sector. We have listened to ideas raised by a number of people we have met, as well as ideas raised in debates in the Commons and in meetings in the Treasury and elsewhere. We have listened, but we remain confident that our approach is a fair way to balance supporting farms and businesses with fixing the public finances, so we stand by our reforms.

I should probably conclude. I thank all hon. Members, particularly the hon. Member for Mid Dunbartonshire, for their contributions to the debate.

Question put and agreed to.