IHTM25510 - AR/BR 100% relief allowance: overview

Introduction 

From 6 April 2026, relief at 100% on the combined value of qualifying agricultural and/or business property is subject to new relief allowances, which cap the value of qualifying property which can get relief at 100%.   

Any value of qualifying agricultural or business property above the available relief allowance gets relief at 50%.  How the relief allowance works depends on the type of gift or trust.    

Individuals 

For individuals, the relief allowance on a chargeable transfer (including death) is £2.5 million, less any amounts already used by chargeable transfers made by the individual in the seven years before (ending with the day of this transfer) (IHTM25520). 

Transitional provisions apply for gifts made on or after 30 October 2024 and before 6 April 2026 (IHTM25521). The relief allowance does not apply to gifts made before 30 October 2024. If the qualifying conditions are met for gifts made before this date, 100% relief is unlimited in value and the amount of relief allowance available for transfers on or after 30 October 2024 is not reduced by any gifts made before that date.  

Unused relief allowance from a late spouse or civil partner may be transferred to the deceased’s estate, provided that a claim is made within four years of the survivor’s death or within six months of the personal representatives starting their role (IHTM25530). 

Qualifying interest in possession settlements are settlements where the life tenant is treated as the beneficial owner of the property comprised in the settlement.  For chargeable transfers on the ending of the qualifying interest in possession, either during the life tenant’s lifetime or on their death, the life tenant’s individual allowance  is relevant, so will be the relief amount less any  amounts already used by chargeable transfers made by the individual in the seven years before (ending with the day of this transfer) (IHTM25522).  

If more than one chargeable transfer is made on the same day, the allowance is apportioned if the total relief exceeds the allowance available (IHTM25523). 

On death, if different titles of the estate qualify for 100% relief, the allowance is apportioned (IHTM25524).  

Settlements 

  • “Pre-commencement settlements” are settlements which contained some agricultural or business property on 30 October 2024 that would qualify for 100% relief at that time but under the post 6 April 2026 rules, ignoring ownership periods.  These settlements get a £2.5m relief allowance for future relevant property charges, even if the settlement was not a relevant property settlement on 30 October 2024 (IHTM25551).  

  • Relevant property settlements (which are not pre-commencement settlements) obtain a relief allowance when a chargeable transfer which qualifies for 100% relief is made by the settlor, up to a maximum of £2.5m during the settlor’s lifetime across all settlements made by the same settlor (IHTM25552). 

  • Special trusts have a £2.5m allowance; this reduces by the amount used on each occasion of charge (IHTM25554).  

  • 18-25 trusts have a £2.5m allowance for each qualifying beneficiary (IHTM25555).  

If more than one chargeable transfer is made on the same day, the allowance is apportioned if the total relief exceeds the allowance available (see example at IHTM25554). 

Unlisted shares 

Additionally, from 6 April 2026, shares in companies listed on a market that does not meet the definition of ‘listed’ for HMRC purposes (such as AIM), only qualify for 50% relief.  

There are transitional provisions for gifts made between 30 October 2024 and 6 April 2026; the 50% relief will only apply if a death occurs within 7 years of the gift (IHTM25570).   

In both cases, this means that these shares are not relevant for the 100% relief allowance.