Where the cost goes
The published data shows the cost of both reliefs is concentrated in a small number of large claims. In 2021 to 2022, the top 4% of business property relief claims, just 158 estates, accounted for 53% of the relief's cost, £558 million, while the top 7% of agricultural property relief claims, 117 estates, accounted for 40% of that relief's cost, £219 million (HMRC/HM Treasury, as at July 2026, subject to change).
By contrast, typical claims are far smaller. The median value of assets qualifying for business property relief was £200,000, and for agricultural property relief £486,000, in the same year; 87% of estates claimed business property below £1 million, and 73% of estates claimed agricultural property below £1 million (HMRC/HM Treasury, as at July 2026, subject to change). The table below sets these distribution figures side by side.
| Measure (2021-22) | Business property relief | Agricultural property relief |
| Largest claims and their share of cost | Top 4% (158 estates) = 53%, £558m | Top 7% (117 estates) = 40%, £219m |
| Median value of qualifying assets | £200,000 | £486,000 |
| Estates claiming below £1 million | 87% | 73% |
Per HMRC and HM Treasury reforms publication, 2021-22, as at July 2026, subject to change. UK-wide.
What changes from 6 April 2026. A new £2.5 million allowance per person applies to the combined value of property qualifying for 100% business or agricultural relief; relief at the lower rate of 50% then applies to qualifying property above £2.5 million (
gov.uk, as at July 2026, subject to change). The allowance is transferable between spouses and civil partners, so a couple can potentially pass on up to £5 million of qualifying business and agricultural property at 100% relief. The £2.5 million figure was confirmed by the government on 23 December 2025, superseding the £1 million (and non-transferable) allowance originally announced at the Autumn Budget 2024 (
HMRC/HM Treasury, as at July 2026, subject to change).
The government has published its own estimate of who is affected. Reflecting the £2.5 million allowance, the reforms are expected to result in up to 1,100 estates across the UK paying more Inheritance Tax in 2026 to 2027. Of these, up to 185 estates claim agricultural property relief (including those also claiming business property relief) and up to around 915 estates claim only business property relief (HMRC/HM Treasury, as at July 2026, subject to change).
| Effect of the reforms (2026-27 forecast) | Figure |
| Estates forecast to pay more IHT | Up to 1,100 |
| Estates claiming agricultural relief (incl. also business) | Up to 185 |
| Estates claiming business relief only | Up to around 915 |
Per HMRC and HM Treasury reforms publication, 2026-27 forecast, as at July 2026, subject to change. UK-wide. Forecasts can be revised at any fiscal event.
What the numbers mean
Read together, the figures describe two reliefs that are individually costly but very unevenly used. Combined, they were estimated to remove around £2.55 billion of Inheritance Tax from the Exchequer in 2024 to 2025, yet the published breakdown for 2021 to 2022 shows a small group of large estates accounting for a disproportionate share, while most claims are for far smaller sums (HMRC, as at July 2026, subject to change).
That pattern helps explain the design of the 2026 reforms, which apply a £2.5 million allowance per person (transferable between spouses and civil partners, up to £5 million per couple) before the rate on qualifying property above it drops to 50% relief. On the government's own forecast, the change affects a small number of estates, up to 1,100 across the UK in 2026 to 2027 (HMRC/HM Treasury, as at July 2026, subject to change). Whether any of this touches a particular family, farm or business depends entirely on the value and make-up of their assets and how they are held, so it can be worth discussing the figures and the new rules with a qualified professional rather than reading a national trend as a personal outcome. These are forecasts and can change at any fiscal event.
Scotland, Wales and Northern Ireland
Inheritance Tax is a UK-wide tax, so business property relief, agricultural property relief, the £2.5 million allowance and the reforms from 6 April 2026 apply the same way in England, Wales, Scotland and Northern Ireland (gov.uk, as at July 2026, subject to change). What differs across the nations is the surrounding law, such as succession and property rules and, in Scotland, distinct land tenure and legal rights, which can affect how a business or farm is owned and passed on. The statistics on this page are collected UK-wide and are not broken down by nation.
Sources and methodology
Every figure on this page comes from a named official source and was checked against that source before publication. No number has been estimated, rounded beyond the source, or extrapolated. Cost figures are HMRC estimates of tax foregone and, for later years, forecasts; where a figure is a forecast it is described as such. The sources used are listed below with their reference periods.
- Cost of the reliefs: HMRC tax relief statistics (January 2026) (business property relief ~£1,400m and agricultural property relief ~£1,150m in 2024-25; ~£1,500m and ~£1,220m forecast for 2025-26).
- Claim concentration and medians: HMRC and HM Treasury, reforms publication (top-claim shares, 158 and 117 estates, £558m and £219m, medians of £200,000 and £486,000, all 2021-22).
- Reform impact: HMRC and HM Treasury, reforms publication (up to 1,100 estates; up to 185 and up to around 915 estates, 2026-27 forecast; £2.5 million allowance and 50% rate above it).
- Relief mechanics and the £2.5m allowance: gov.uk, What qualifies for Business Relief (100% and 50% rates; £2.5 million per-person allowance for 100% relief, transferable between spouses and civil partners, for deaths on or after 6 April 2026; £2.5 million figure confirmed 23 December 2025, superseding the £1 million announced at Autumn Budget 2024).
- Core rates and threshold: gov.uk, Inheritance Tax (£325,000 nil-rate band, 40%/36% rates).
Frequently asked questions
How much do business and agricultural relief cost the Exchequer?
HMRC estimated business property relief at around £1,400 million and agricultural property relief at around £1,150 million of Inheritance Tax foregone in 2024 to 2025, with both forecast higher in 2025 to 2026 (HMRC, as at July 2026, subject to change). These are estimates of tax not collected and can be revised as more data arrives.
Are the largest claims a big share of the cost?
Yes. In 2021 to 2022 the top 4% of business property relief claims, 158 estates, took 53% of that relief's cost, £558 million, and the top 7% of agricultural property relief claims, 117 estates, took 40%, £219 million (HMRC/HM Treasury, as at July 2026, subject to change). Most claims are for much smaller amounts.
What is the typical size of a claim?
In 2021 to 2022 the median value of assets qualifying for business property relief was £200,000, and for agricultural property relief £486,000; 87% of estates claimed business property below £1 million and 73% claimed agricultural property below £1 million (HMRC/HM Treasury, as at July 2026, subject to change). Most claims are therefore modest by value.
How many estates will pay more Inheritance Tax after the 2026 reforms?
The government forecasts that up to 1,100 estates across the UK will pay more Inheritance Tax in 2026 to 2027 as a result of the reforms, reflecting the £2.5 million allowance (HMRC/HM Treasury, as at July 2026, subject to change). This is a forecast and can be revised.
What is changing from 6 April 2026?
From 6 April 2026 a new £2.5 million allowance per person applies to the combined value of property qualifying for 100% business or agricultural relief, with relief at 50% on qualifying property above £2.5 million (gov.uk, as at July 2026, subject to change). The allowance is transferable between spouses and civil partners, giving a couple up to £5 million at 100% relief. The £2.5 million figure was confirmed on 23 December 2025, replacing the £1 million (non-transferable) allowance originally announced at Autumn Budget 2024. How this affects a given estate depends on its assets.
Do these reliefs work the same across the UK?
Yes. Inheritance Tax is a UK-wide tax, so business and agricultural relief, the £2.5 million allowance and the reforms apply the same way in England, Wales, Scotland and Northern Ireland (gov.uk, as at July 2026, subject to change). Surrounding succession and property rules can differ between the nations, particularly in Scotland, which can affect how a business or farm is owned and passed on.
About Fairchild Oldfield
The Fairchild Oldfield team brings together estate planning, tax, independent financial advice and client care, working with families across England and Wales.
Fairchild Oldfield are estate planning specialists and will writers, not a firm of solicitors. This article is general information based on practical experience, not legal, tax or financial advice.
Important: This article is general information only and is not legal, tax or financial advice. Reading it does not create a professional relationship. It is based on the law of England and Wales, and other UK jurisdictions may differ. Figures and rules are current as at July 2026 and are subject to change. Before acting, many people choose to seek advice from a suitably qualified professional, such as a solicitor, a STEP practitioner, an accountant, or an FCA-authorised financial adviser, who can consider your individual circumstances.