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Reforms to IHT reliefs: consultation on property settled into trust

HMRC has launched a consultation on the proposed reforms to agricultural property relief and business property relief from 6 April 2026, focusing specifically on their application in relation to trusts.

HMRC is seeking views on the application of a £1 million allowance for property settled into trust that qualifies for 100% agricultural property relief or business property relief. The changes are set to take effect from 6 April 2026, with transitional provisions for transfers made before this date. The consultation also addresses the introduction of an anti-fragmentation rule to prevent the division of property into multiple trusts to avoid tax liabilities. The consultation closes on 23 April 2025.

See Simon’s Taxes I7.103, I7.304.

Co-ownership Contractual Schemes (Tax) Regulations, SI 2025/200

These Regulations set out the tax rules for the reserved investor fund (RIF) and make associated changes to the tax rules for co-ownership authorised contractual schemes (CoACS).

These Regulations:

1. •

   set out the tax rules for investors in a new type of investment