Tailored · Discreet · Secure

Inheritance Tax Reforms

UK Inheritance Tax Reforms 2025 to 2027: What Is Changing and When

Four reforms land between April 2025 and April 2027. Here is the full timeline, with the two figures most guides still get wrong.

7 min read · Written by the Fairchild Oldfield team · Last reviewed: August 2026

£2.5m
The corrected cap for 100% farm and business relief per person from 6 April 2026, transferable to £5m per couple. Confirmed 23 December 2025, it replaced the £1m figure most reform summaries still quote.
Source: gov.uk, APR and BPR reforms, as at August 2026, subject to change.

The UK inheritance tax reforms of 2025 to 2027 change who is caught, how farms and family businesses are relieved, and whether a pension counts as part of your estate. The 40% rate and the £325,000 nil-rate band stay put. Two of the most-quoted figures have moved since first announced, and many guides still show the old numbers. General information for England and Wales, not advice.

What are the current UK inheritance tax reforms, and when do they take effect?

Four inheritance tax reforms are rolling out in the UK: a residence-based system replacing domicile from 6 April 2025, a cap on farm and business relief from 6 April 2026, unused pensions brought inside estates from 6 April 2027, and the nil-rate bands frozen until 5 April 2031. The rate stays at 40%, or 36% where at least 10% of the estate passes to charity.
ReformWhat changesTakes effect
Residence-based systemLong-term UK residence, not domicile, decides whether worldwide assets are taxed6 April 2025
Farm and business relief cap100% relief on the first £2.5m per person, 50% above that (raised from £1m)6 April 2026
Unused pensions in the estateMost unused pension funds and death benefits count as part of the estate6 April 2027
Threshold freeze extended£325,000 NRB and up to £175,000 RNRB held until 5 April 2031In force now

Source: gov.uk, Inheritance Tax and Autumn Budget 2025, as at August 2026, subject to change.

Taken together, these reforms widen the base rather than raise the rate. More estates pay because thresholds are frozen while asset values rise, and two large asset classes, farms or businesses and pensions, lose part of their old shelter.

What is the new residence-based inheritance tax system from April 2025?

From 6 April 2025, domicile no longer decides your inheritance tax exposure on non-UK assets. A residence test applies instead: a person resident in the UK for at least 10 of the previous 20 tax years is a long-term resident and is taxed on worldwide assets. Those below that threshold are generally taxed only on UK assets.

This mainly affects internationally mobile families and long-settled non-domiciled residents, who now come into worldwide scope after 10 years rather than the old 15. UK-situated assets, such as a home in England or Wales, were always in scope and remain so.

There is also a tail after leaving the UK. Someone resident between 10 and 13 years falls outside the net on non-UK assets after three tax years abroad, and that tail lengthens with each further year of residence up to a maximum of 10 years for the longest-resident individuals.

Source: gov.uk, reforming the taxation of non-UK domiciled individuals, as at August 2026, subject to change.

How is farm and business relief changing, and why is £1m wrong?

From 6 April 2026, Agricultural Property Relief and Business Property Relief give 100% relief only on the first £2.5m of combined qualifying value per person, with 50% relief above that. The allowance is transferable between spouses, up to £5m per couple. Most reform guides still quote a £1m cap, which was the first announcement and was later raised.

The £1m figure came from the Autumn Budget 2025 on 26 November 2025. It was superseded on 23 December 2025, when the government confirmed the higher £2.5m per person allowance. Because most summaries were written in the weeks in between, the old number is still circulating and understates the relief now available.

FeatureFirst announced (26 Nov 2025)Confirmed (23 Dec 2025)
100% relief cap per person£1m£2.5m
Transferable to a spouseYesYes, up to £5m per couple
Relief above the cap50%50%
Effective date6 April 20266 April 2026

Source: gov.uk, APR and BPR reforms, as at August 2026, subject to change.

Value above the cap is relieved at 50%, giving an effective 20% inheritance tax charge on that excess. A farm or family company left over the £2.5m line therefore keeps meaningful relief, but not the full shelter it had before. We cover the detail in inheritance tax on farms from April 2026.

Why will unused pensions face inheritance tax from April 2027?

From 6 April 2027, most unused pension funds and lump sum death benefits are added to your estate and can be taxed at 40% above your available bands. Pensions left to a spouse or civil partner keep the spousal exemption. The charge usually arises where a pension passes to children or others, alongside the rest of the estate.

This is the reform that reaches ordinary savers. A pension that once sat outside inheritance tax may now be counted next to the house. Your executors, not the pension scheme, report and pay the charge, so an estate needs enough cash to settle a bill before assets are sold. A worked example sits in pensions and inheritance tax from 2027.

Source: gov.uk, Inheritance Tax on pensions technical note, as at August 2026, subject to change.

How long are the inheritance tax thresholds frozen?

Until 5 April 2031. The Autumn Budget 2025 extended the freeze on the £325,000 nil-rate band, the residence nil-rate band of up to £175,000, and the £2m taper threshold by a further year. They were previously due to thaw in 2030. Many older articles still say 2029-30 or 2030.

A single person can pass up to £500,000 free of inheritance tax where a home goes to children or grandchildren, and a couple up to £1m combined. The residence band is withdrawn by £1 for every £2 an estate exceeds £2m, so it tapers away entirely on larger estates (how inheritance tax works).

Source: gov.uk, Inheritance Tax, as at August 2026, subject to change.

What do the reforms mean for a typical estate, and what should you do?

For most homeowning families, the residence-based and farm relief reforms do not apply, but the 2027 pension change and the frozen bands often do. A couple with a home and pensions can still be inside the net once the pension is counted. The practical response is to check the bands, review pension nominations, and use the gift exemptions that survived untouched.

Consider a widow in England with a £450,000 home passing to her children and a £250,000 unused pension. Before April 2027 the pension sits outside inheritance tax. From April 2027 it is added, giving a £700,000 estate. Her own bands (£325,000 plus £175,000 residence band) and the £325,000 nil-rate band inherited from her late husband cover it, so no tax is due here. Push the pension or home higher, though, and the frozen bands are quickly exceeded.

  1. Confirm which reforms reach you. The residence-based and farm relief changes affect a minority of estates. Most families are touched only by the pension change and the frozen bands.
  2. Correct any plan built on £1m. If farm or business planning assumed a £1m relief cap, revisit it against the confirmed £2.5m per person, £5m per couple.
  3. Review your pension nominations. A pension left to a spouse or civil partner stays exempt from April 2027, so check your expression of wishes reflects who you intend to benefit.
  4. Use the gift exemptions that still stand. The £3,000 annual exemption, £250 small gifts and the seven-year rule with taper on the tax were untouched (how much you can gift tax free).
  5. Take joined-up advice before large moves. These taxes interact, so a financial adviser and your estate planner are best consulted together before emptying a pension or restructuring a business.

Most people fold these checks into their wider estate planning. For a discreet review, you can book a consultation or see our fixed pricing.

Frequently asked questions

Common questions on the UK inheritance tax reforms cover the new residence rules, the farm relief figure, the 2027 pension change, and the freeze end date. Answers below are based on gov.uk guidance, current as at August 2026 and subject to change.

What are the new inheritance tax rules in the UK?

Four reforms are rolling out: a residence-based system from 6 April 2025 that replaces domicile, a cap on farm and business relief from 6 April 2026, unused pensions brought inside estates from 6 April 2027, and the nil-rate bands frozen until 5 April 2031. The 40% rate and the £325,000 nil-rate band are unchanged.

Is the £1 million farm and business relief cap still correct?

No. The £1m figure was the first announcement on 26 November 2025. On 23 December 2025 the government confirmed the cap starts at £2.5m per person, transferable to £5m per couple, from 6 April 2026. Value above the cap keeps 50% relief. Many reform summaries still show the old £1m number.

When do pensions become subject to inheritance tax?

From 6 April 2027. Most unused pension funds and lump sum death benefits will count as part of your estate and can be charged at 40% above your available bands. Pensions passing to a spouse or civil partner keep the spousal exemption, so the charge tends to arise where a pension goes to children or others.

How long are the inheritance tax thresholds frozen for?

Until 5 April 2031. The Autumn Budget 2025 extended the freeze on the £325,000 nil-rate band, the residence nil-rate band of up to £175,000, and the £2m taper threshold by a further year, having previously been due to end in 2030 (gov.uk, as at August 2026, subject to change).

Who does the new residence-based inheritance tax system affect?

Mainly internationally mobile individuals and long-settled non-domiciled residents. From 6 April 2025, a person resident in the UK for at least 10 of the previous 20 tax years is a long-term resident and taxed on worldwide assets. UK-situated assets, such as a home in England and Wales, were always in scope.

About Fairchild Oldfield

The Fairchild Oldfield team brings together estate planning, tax awareness and client care, working discreetly 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 describes the law of England and Wales, and other UK jurisdictions may differ. Figures and rules are current as at August 2026 and are subject to change. Several reform measures are set out in draft and may be amended before they take effect. 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 their individual circumstances.

See how the reforms affect your estate

Wills, tax awareness and a clear plan, considered together with one discreet point of contact.

Book a Free Consultation