The Autumn 2024 Budget brought the most significant changes to inheritance tax in a generation. Announced by Chancellor Rachel Reeves on 30 October 2024, the reforms will affect millions of families who had previously assumed they were outside the scope of IHT or had structured their affairs in ways that no longer provide the same level of protection.
If you have not reviewed your estate plan since October 2024, the rules you were working to may no longer apply. This article explains what has changed, who is affected, and what practical steps are worth considering now.
A Quick Recap of How IHT Works
Before looking at what has changed, it helps to understand the baseline. Inheritance tax is charged at 40% on the value of an estate above the available nil rate band. Everyone has a nil rate band of £325,000. If you leave your main residence to direct descendants — children or grandchildren — you also benefit from the residence nil rate band of £175,000. For a married couple or civil partners, both allowances can be transferred on the first death, potentially giving a combined allowance of £1 million before IHT applies.
That is the existing framework. The Budget changes layer significant new restrictions on top of it, primarily affecting pensions, agricultural land, and business assets.
The Pension Change: The Biggest Shift in Decades
The most far-reaching change in the Budget was the announcement that unused pension funds will be brought into the scope of inheritance tax from April 2027. This reverses the position that has applied since 2015, when pension freedoms made defined contribution pensions one of the most powerful intergenerational wealth transfer vehicles available.
Under the old rules, if you died before age 75 with money remaining in your pension, your beneficiaries could inherit it completely free of income tax and outside your estate for IHT purposes. Even after 75, the funds fell outside your estate, and beneficiaries paid only income tax when they drew them down. For many people, this made pensions the last asset they wanted to touch in retirement — a pot kept deliberately full to pass on to children.
From April 2027, unused pension funds will form part of your taxable estate. A married couple with a combined estate of £900,000 including £200,000 in pension funds would previously have faced no IHT. Under the new rules, depending on how the allowances apply, the picture changes materially. The full detail of how pension administrators will interact with HMRC to calculate and collect the tax is still being consulted on, but the direction of travel is clear.
What does this mean in practice? If you have been deliberately preserving a pension pot as an inheritance vehicle, the case for doing so has weakened significantly. This does not mean drawing everything down immediately — income tax on withdrawal still applies, and the interaction between income tax on drawdown and IHT on death needs careful modelling. But it does mean the planning conversation around pensions has fundamentally changed, and anyone who built a retirement income strategy around the idea of a pension-as-inheritance should revisit it.
Agricultural Property Relief and Business Property Relief Changes
From April 2026, the 100% relief currently available on qualifying agricultural and business assets will be capped at £1 million per person. Assets above that threshold will attract relief at only 50%, meaning the effective IHT rate on those excess assets will be 20% rather than zero.
For farming families, this is a profound change. A working farm with land, buildings and equipment valued at £3 million — not an unusual figure in many parts of England — would previously have passed entirely IHT-free to the next generation. Under the new rules, £2 million of that value above the £1 million cap would attract an IHT charge at the reduced rate, producing a potential bill of £400,000.
The concern for many farming families is liquidity. Land does not come with a cash payment attached. Paying an IHT bill of several hundred thousand pounds may require selling assets — and for a working farm, selling assets often means selling the means of production. The government has announced that qualifying agricultural and business assets above the cap will be eligible for ten-year instalment payments, which reduces the immediate cash pressure but does not eliminate the underlying liability.
For business owners, the position is similar. A trading company worth £2 million previously passed IHT-free. From April 2026, the excess over £1 million attracts 20% tax. Shares in AIM-listed companies, which qualified for Business Property Relief at 100% after two years of ownership, will now only attract 50% relief — making AIM portfolios less efficient as IHT planning tools than they were.
What Has Not Changed
A number of the core structures remain intact and continue to offer genuine planning opportunities. The nil rate band and residence nil rate band have not changed, though they remain frozen until at least 2030, meaning more estates will be caught as property values rise. Gifts made more than seven years before death remain outside your estate. The annual gift exemption of £3,000 per person, the small gifts exemption, and gifts from surplus income remain available. Trusts continue to offer legitimate planning structures, though they carry their own tax charges and require careful advice.
Charitable giving remains fully exempt from IHT, and the reduced 36% rate for estates leaving at least 10% to charity still applies.
What Should You Actually Do?
The honest answer is that the right response depends entirely on your personal circumstances. There is no universal solution. But there are several conversations worth having now, before April 2026 and April 2027 arrive.
First, if your estate plan assumed that pension funds would sit outside IHT, that assumption needs revisiting. Your retirement income strategy may need to be reordered — which assets you draw on first, which you preserve, and in what sequence. This requires proper cashflow modelling rather than guesswork.
Second, if you own agricultural land or a trading business, the impact of the April 2026 changes on your specific position needs to be quantified now. With roughly twelve months until the change takes effect, there is still time to review structures, consider gifting strategies and assess whether instalment arrangements are likely to be relevant.
Third, if you have an AIM portfolio held primarily for IHT purposes, the 50% relief from April 2026 does not make it worthless — but it does change the calculation, and a review of whether the portfolio still serves its original purpose makes sense.
Fourth, and most broadly, if you have not had a comprehensive estate planning review in the last two years, now is the time. The landscape has changed substantially, and plans built on the previous rules may be significantly less effective than their authors intended.
IHT planning done well is not about aggressive avoidance. It is about making sure that the wealth you have built passes to the people you intend, in the most efficient way possible, within the rules as they stand. The rules have changed. The plans need to catch up.
This article is for general information only and does not constitute regulated financial advice. IHT rules are complex and depend on individual circumstances. If you would like to discuss your own position, I am happy to have a free initial conversation.