Clause 1

Robbie Moore Excerpts

Monday 12th January 2026 Commons Chamber

[Dan Tomlinson]

The Government do support the farming sector and the farming industry. We will continue to do so through the funds that we will make available via DEFRA—funds that were not fully spent under the previous Government. We have listened to farming communities and business representatives, and raised the threshold from £1 million to £2.5 million as a result of that listening and engagement. The Government do not think it would be right to abolish the policy in full, because then we would forgo £300 million of revenue from the very largest estates. [Interruption.] The hon. Member for North Dorset (Simon Hoare) may say that £300 million is a rounding error, but it is important to raise revenue from a broad range of taxes, and from those with the largest-value estates in the country. As I said earlier, hundreds of millions of pounds in tax is relieved from the very largest estates in the country. If Opposition Members want that to continue to be the case, that is of course their right, but we Government Members think that our reforms are fair, and raise proportionate revenue from the very largest estates.

[Robbie Moore (Keighley and Ilkley) (Con)]

Can the Minister explain how we ended up in the bizarre scenario in which two estates—I use the term “estates”, because they need not necessarily be farming businesses; they could be any kind of family business estate—valued at £5 million could generate different amounts of tax for the Treasury, depending on the ownership structure? Secondly, can he explain, because I cannot see this in the amendments that have been tabled, why there is no indexation link to any increase? Obviously, land values will increase over time. Thirdly, when he was last at the Dispatch Box, he said that interest would not be charged, so can he clarify whether, when inheritance tax liability is triggered, interest is or is not triggered in that 10-year period?

[Dan Tomlinson]

There were some forensic questions in that not brief intervention, but of course I appreciate it, and I look forward to trying to go through—[Interruption.] I am trying to answer the questions, okay? [Interruption.] It is a bit difficult when Opposition Front Benchers continue to barrack me while I am trying to answer the questions that a Back-Bencher has asked. If the right hon. Member for Louth and Horncastle (Victoria Atkins) wishes to continue to hector me from a sedentary position, she may, but we will not have any time for me to answer questions.

On the points raised by the hon. Member for Keighley and Ilkley (Robbie Moore)—let me dial down the temperature; congratulations for getting to me—and on how the spousal transfer is used in the inheritance tax system, we are replicating that in the treatment of the spousal transfer for APR and BPR. That is the way the transfer is set out in the inheritance tax system. We are not doing anything different or novel here. We just debated the thresholds, which will be set at current levels and will not be uprated in line with the changes that we are making to other taxes. The hon. Gentleman also asked about interest. As I said, where inheritance tax is due, those liable for a charge can pay any liability on the relevant assets over 10 annual instalments, if they like, and that will be interest-free. I have been through the numbers. Only 185 additional estates claiming APR are expected to pay more in 2026.

To conclude, the reforms get the balance right between supporting farms and businesses, fixing the public finances, and funding our public services.

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[Gareth Davies]

I completely agree. We would not be doing this, and we should not be here, but clearly the policy has been executed without a plan—without serious thought, analysis or engagement. I would welcome anything that the Government can do to make this less painful for those affected and to get the numbers right.

The Minister explained that the Government expect to raise around £300 million even with the U-turn, but the initial costing was labelled in the OBR’s economic and fiscal outlook as “highly uncertain”. For those not familiar with this, there are different categories of uncertainty in the EFO, and “highly uncertain” is the most uncertain that one can be about a figure. Surely this new figure of £300 million is uncertain, just as the £500 million was. What assurance can the Minister provide that the Exchequer will not in fact lose out overall, despite the pain that the Government are determined to inflict? How confident is he in these numbers?

Secondly, since the Chancellor’s first Budget, family businesses and farmers have had to make many difficult decisions. Family Business UK and Make UK say that 55% of BPR-affected and 49% of APR-affected businesses have paused or cancelled investments. Family-run farms are putting off the purchase of new, more efficient machinery and family-run shops no longer see the point of expanding to an additional site or another high street, or of taking on more staff. It comes back to the questionable figures I talked about and the CBI’s analysis of the impact on the wider economy.

Finally, we should have no confidence in the practicality of the measures before us. The Chartered Institute of Taxation has warned that extending 10 annual interest-free instalments to APR and BPR property does not solve the problem; those instalments will still be a significant burden. In practice, it is unlikely that many families will be able to pay the tax without selling up.

[Robbie Moore]

On practicalities, I would be interested to understand whether the Minister or the Treasury has done any analysis of the impact on the district valuer. There is a real challenge in that when a farm is valued, that value will be disputed by either the Treasury or the agent acting on behalf of the landowner with that tax liability. Secondly, if we look at two farms in different parts of the country, we see that values vary dramatically. What consideration does my hon. Friend think the Treasury has given to how tax liability varies based on the value of 200 acres of land in one part of the country and 200 acres valued at a higher rate, such as in Northern Ireland? Practicalities matter.

[Gareth Davies]

That is exactly right. I will let the Minister address that point, but let me pay tribute again to my hon. Friend, who has been a forceful champion for farmers across the country and has consistently raised these issues. That goes back to my point about the warnings provided to the Government about the practical implications of the changes, with their impact on family farms in particular. They were ignored until this point. The Minister will have to explain why that was.

Indeed, the Chartered Institute of Taxation has warned that schedule 12’s failure to allow allowances to be allocated to specific property could undermine many wills as currently drafted. This creates a tremendous amount of uncertainty, disputes and real hardship.

Where the cap is exceeded, the first inheritance tax payment will fall just six months after death. If that deadline is missed, the estate will be hit with a punishing interest rate. Within six months, family farms must secure probate, value complex agricultural and business assets, calculate the liability and then raise the cash—often by selling parts of the estate to make the first payment. The NFU has been clear that expecting probate within six months is “unrealistic” given the complexity of valuing agricultural businesses, as my hon. Friend pointed out. In practice, families and personal representatives will miss the deadline—through no fault of their own—without a confirmed tax bill and without the funds to pay for it.

The Government’s expectation is simply unrealistic. The approach is flawed, and the window must be extended. If clause 62 is agreed to and the Government do not finally concede, family farmers and businesses in my community of Lincolnshire and those across the country will not rest until these changes are fully reversed. The only consolation I can offer farmers and businesses watching the votes closely tonight—they will be watching every single one—is that the next Conservative Government will scrap these immoral changes.

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[David Smith]

I thank my constituency neighbour for his intervention. Rather than go down the route of his question, let me respond with the words of one of my local farmers. She wrote to me on 23 December and said:

“As you know, we have been very vocal in opposing the earlier proposals, so it is equally important to state how strongly we welcome this change in policy. Increasing the threshold, together with the ability to retrospectively transfer unused APR and BPR allowances from my late mother to my father, will make a huge difference to our family and the viability of our farm business.

I will leave my remarks there.

[Robbie Moore]

I will speak to clause 62, schedule 12 and the amendments to them tabled by the Conservative Front Benchers.

Throughout debate on the Finance Bill, we have heard about the changes to inheritance tax, predominantly in relation to the agricultural and business property reliefs. My comments refer not only to the many family farming businesses affected by the Government’s changes, but to many other family businesses, be they hospitality or manufacturing businesses, including in my Keighley constituency. They are all affected by the direction that the Labour Government are taking.

The changes that the Government have brought to the Committee do not get rid of the cliff edge associated with the measure kicking in a few months from now in April. Changing the threshold from £1 million to £2.5 million does not remove that cliff edge for a family business that has an IHT liability kicking in. I would like the Minister to explain further why the Government are not addressing that stark cliff edge, even though Members from all Opposition parties have reiterated that problem to the Government over the past 14 months.

The second matter I will raise is the absolutely bizarre and bonkers scenario that we find ourselves in. Two estates valued at £5 million could be subject to different tax liabilities depending on the ownership structure. How bizarre is it that we now find ourselves in a scenario in which an estate valued at over and above £2.5 million and owned by a single person could be subject to an IHT liability of 20%, but a farm valued at £5 million and owned by a married couple is subject to no IHT liability at all? I would like further explanation from the Minister on that specific point.

Of course, values vary dramatically across the country. In Northern Ireland, where most farmland assets are given very high valuations, farms of 200 acres, say, could be valued significantly more or less in different parts of the country, so they would be subject to different tax liabilities if they surpassed the £2.5 million and £5 million thresholds, depending on their ownership structures. Let us not forget that, for arable farmers, feed wheat prices have not changed dramatically over the past 20 years—they still average about the same—but input prices are going up, no thanks to this Government’s raising of employer national insurance contributions and imposition of the fertiliser tax. In reality, the productivity and return rate for a farming business, if it breaks even at all, is about 1%. Those with asset base that is valued significantly higher will be subject to a higher tax liability, and they will have to sell off more assets to pay the same amount, despite their level of return being 1%, if that. That is different from a farm that has been valued at a much lower rate. Will the Minister explain what level of detail the Government have gone into to explore such challenges that are facing many farming businesses?

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[Lizzi Collinge (Morecambe and Lunesdale) (Lab)]

As someone who represents a large semi-rural constituency, I am glad to have this opportunity to speak about the changes to agricultural and business property relief and why they matter for farming families and for fairness in our tax system. I welcome these changes, which recognise the reality of the asset-rich, but cash-poor nature of farming, where land might be worth a lot of money by most people’s standards, but that value cannot be realised in cash terms unless it is sold, particularly for non-farming use.

The aim of this inheritance tax policy is simple: fairness for hard-working family farms, but no open-ended tax breaks for the wealthiest. The Government are reforming outdated tax relief rules to ensure that the very largest estates make a fair contribution. Under these changes, small and medium-sized agricultural estates will remain unaffected by inheritance tax, with full relief still applying up to £2.5 million for an individual, rising to £5 million for a married couple, who will be able to transfer their allowances to each other, as is the case for personal inheritance tax. I am slightly surprised that those on the Conservative Benches are only now discovering that concept, given that it has been standard for many years.

What will change is the ability for the ultra-wealthy and the very largest estates to use agricultural land as a tax planning tool, driving up land prices and shutting out genuine farmers, while making little or no contribution in return. The farmers I have spent time with—over many meetings in village halls, at farmhouses and at the Westmorland county show, which I highly recommend—were clear that they understood the need to prevent the ultra-wealthy avoiding tax, but they were rightly concerned that the threshold of £1 million, as originally proposed, would inadvertently catch ordinary family farms. Local farmers and solicitors were extremely generous in sharing their financial information with me, which was sent directly to the Treasury. It showed the reality of the finances of farming.

I must make special mention of a local Labour party member, Karenna Caun, who organised for that information to be gathered and who helped me to reach out to farmers and related businesses, particularly in the Lune valley. The NFU and others have already recognised that these changes materially improved the position for farming families. These changes have taken on board concerns raised by rural Labour MPs, but with these reforms targeted at the biggest estates, the Government expect to raise £300 million a year by the end of the decade. That is money we can put into local GP services, rural bus services and village schools, giving our children the best start in life. Yes, some of the largest estates will pay more after these changes.

[Robbie Moore]

The hon. Lady has mentioned, I think two or three times, that it will be possible for the ultra-wealthy to be exposed to the inheritance tax liability. However, having a huge asset base that may be worth a great deal of money does not mean having a good income. A business could have a cash flow that is not generating any revenue to keep that business going. Is she classifying businesses and farming families in her constituency who might have an asset base of over £1 million as very wealthy people?

[Lizzi Collinge]

I suspect that the hon. Gentleman missed the third paragraph of my speech, in which I talked about the asset-rich but cash-poor nature of farming. Land may be worth a lot of money according to most people’s standards, but it may not be possible to realise the value in cash terms unless the land is sold, especially for non-farming uses. As he knows, I am talking about the threshold that has now been set at £2.5 million for individuals and £5 million for couples, not the £1 million threshold that I and many of my colleagues have succeeded in changing.

I make no apology for supporting a progressive policy that closes tax loopholes for the wealthy. I am thinking of people such as James Dyson, who talked proudly about buying up agricultural land in order to avoid tax. How can anyone defend multimillion-pound estates paying zero inheritance tax, when we are digging ourselves out of the fiscal and social hole made by 14 years of Conservative government?

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[Robbie Moore]

I hope that the Minister will answer my question, which I have asked twice in this debate, about indexation and the scenario in which two estates valued at £5 million are subject to different IHT liabilities depending on their ownership structures. Given that this issue is so important, not only to our farming community but to family businesses more broadly, why on earth did the Chancellor not announce this change at the Budget? It seems very peculiar to make a big fiscal change outside of a Budget announcement.

[Dan Tomlinson]

I will come shortly to the questions that the hon. Gentleman asked.

The Liberal Democrat spokesperson, the hon. Member for Witney (Charlie Maynard), mentioned the costs of administrating the tax changes. Those costs were published in a tax impact and information note, alongside the changes: £9.2 million is the figure that the Government published. On the sustainable farming incentive, which he and others mentioned, he may have missed the update that Secretary of State for Environment, Food and Rural Affairs provided last week, which the NFU said showed

“real ambition for a thriving agriculture industry”.

The hon. Members for Keighley and Ilkley (Robbie Moore), for Upper Bann (Carla Lockhart), and others, mentioned that the allowance is only transferrable between spouses. That is in line with the long-standing approach to inheritance tax. The inheritance tax nil rate band and the residence nil rate band are also only transferrable between spouses and civil partners.