Wills & Estate Planning for Farmers and Rural Landowners

Agricultural Property Relief (APR) is an inheritance tax relief that can reduce or eliminate the IHT payable on qualifying agricultural property. Agricultural land and buildings used for farming can qualify for 100% relief (if owner-occupied) or 50% relief (if let to a tenant). However, the relief only applies to the agricultural value of the property — not any development value or non-agricultural element. We advise on APR eligibility and how to structure your estate to maximise the relief available.

From 6 April 2026, Agricultural Property Relief and Business Property Relief are subject to a combined allowance of £2.5 million at the 100% relief rate. Assets above this combined threshold will only attract 50% relief — meaning IHT will be payable at an effective rate of 20% on the excess. For a farm worth £4 million, this could mean a significant IHT liability where previously there would have been none. Farming families who have relied on APR to protect their estate need to review their position now.

Keeping a farm together while providing for all family members — including non-farming children — requires careful will drafting and trust planning. Options include leaving the farm to the farming successor with specific legacies or life insurance for non-farming children; using a discretionary trust to provide flexibility; and lifetime gifting of agricultural land (subject to the seven-year rule for IHT purposes). We advise on the full range of options available to farming families.

Agricultural land let to a tenant can qualify for APR, but generally only at 50% rather than 100%. The 100% rate applies to owner-occupied agricultural land. There are exceptions — including land let on tenancies granted on or after 1 September 1995 — but the rules are complex. We advise on the relief available for let agricultural land and strategies to maximise it.

If you die without a will, your farm will pass under the intestacy rules — which may not reflect your wishes and could result in the farm being divided between multiple beneficiaries. This can make it impossible to keep the farm together and may force a sale. Making a will that specifically addresses the farm and your succession intentions is essential for any farming family.

Yes — discretionary trusts can provide flexibility for farming families, particularly where the farming successor is not yet identified or where non-farming children need to be provided for without a forced sale. A trust can hold the farm for the benefit of multiple family members while ensuring the farming successor has the right to manage and eventually own it. We advise on trust structures for farming estates as part of a wider succession planning review.

Agricultural Property Relief applies to the agricultural value of agricultural land and buildings. Business Property Relief applies to the business element of a farming enterprise — including farm machinery, livestock, and the business goodwill. Many farming businesses qualify for both reliefs on different elements of the estate. The 2024 Budget changes mean that APR and BPR now share a combined £2.5 million allowance at the 100% rate, which affects estates that previously relied on both reliefs.