Interaction of APR and BPR

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance

Interaction of APR and BPR

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance
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This guidance note considers the interaction of APR and BPR. Sometimes APR and BPR may be available on the same assets and sometimes only one relief may be available. This note considers which relief will apply and which assets may not qualify. A farming business or landed estate may qualify for relief in its entirety by using BPR to ‘mop up’ the excess value, even where it holds assets that do not qualify for APR in their own right. Shares in farming companies may qualify for BPR rather than APR or neither relief if the land is let. Consideration is also given to the replacement of assets for BPR purposes where assets qualifying for APR are replaced with assets qualifying for BPR or vice versa.

APR and BPR 100% rate cap

From 6 April 2026, the 100% rate of relief for BPR and APR will be restricted. 100% relief will only be available on the first £1m of relievable property and any value in excess of this will be relieved at 50%. See

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