Contribution
With this it will be convenient to consider the following:
Amendment 42, in schedule 12, page 443, line 13, leave out from “and” to end of line 16 and insert—
“(c) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% relief allowance available in relation to that chargeable transfer (see section 124D),”
This amendment would maintain 100% business relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.
Amendment 45, page 443, line 13, leave out from “and” to end of line 16, and insert—
“(c) either—
(i) is attributable to property acquired before 31 March 2026, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% relief allowance available in relation to that chargeable transfer (see section 124D),”
This amendment would apply 100% business property trust relief where the property was acquired before 31 March 2026.
Amendment 43, page 443, line 22, leave out from “and” to end of line 25 and insert—
“(c) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% trust relief allowance available in relation to that occasion (see sections 124G to 124K),”
This amendment would maintain 100% business relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.
Amendment 46, page 443, line 22, leave out from “and” to end of line 25 and insert—
“(c) either—
(i) is attributable to property acquired before 31 March 2026, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% trust relief allowance available in relation to that occasion (see sections 124G to 124K),”
This amendment would apply 100% business property trust relief where the property was acquired before 31 March 2026.
Amendment 44, page 443, line 37, leave out from “and” to end of line 3 on page 444 and insert—
“(b) either—
(i) is attributable to property that has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% relief allowance available in relation to that chargeable transfer (see section 124D),”
This amendment would apply 100% agricultural property trust relief where the property has been owned by the transferor for at least 10 years as part of a business that is actively operated by the transferor or a member of their family.
Amendment 47, page 443, line 37, leave out from “and” to end of line 3 on page 444 and insert—
“(b) either—
(i) is attributable to property acquired before 31 March 2026, or
(ii) if the value does not fall within (i), does not exceed the amount of the 100% relief allowance available in relation to that chargeable transfer (see section 124D),””
This amendment would apply 100% business property trust relief where the property was acquired before 31 March 2026.
Amendment 48, page 444, line 15, at end insert—
“(1D) Where the whole or part of the value transferred is treated as reduced by 50% under subsection (1), the resulting inheritance tax liability is chargeable only if, within 10 years of the relevant transfer, the agricultural land giving rise to the charge is either—
(a) sold (and the owner has not purchased agricultural land elsewhere), or
(b) ceased to be used for farming.”
Government amendments 24 to 26.
Amendment 3, in schedule 12, page 451, line 22, leave out “30 October 2024” and insert “1 March 2027”.
This amendment, along with amendments 4 to 23 would remove the transition period in respect of the changes to agricultural property and business property relief and delay the implementation date so that the changes would take effect for transfers made after 1 March 2027.
Amendment 31, page 451, line 22, leave out “30 October 2024” and insert “6 April 2026”.
This amendment, with Amendments 32 to 36, would remove the transition period in respect of the changes to agricultural property and business property relief so that the changes take effect for transfers made from 6 April 2026.
Amendment 4, page 452, line 3, leave out “30 October 2024” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 32, page 452, line 3, leave out “30 October 2024” and insert “6 April 2026”
See explanatory statement for Amendment 31.
Government amendments 27 to 29.
Amendment 5, in schedule 12, page 454, line 17, leave out “30 October 2024” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 33, page 454, line 17, leave out “30 October 2024” and insert “6 April 2026”
See explanatory statement for Amendment 31.
Amendment 40, page 455, line 31, leave out “2031” and insert “2027”
This amendment would begin indexation in 2027 rather than 2031.
Amendment 41, page 455, line 33, at end insert—
“(2A) If the Treasury estimates that the value of agricultural land has increased by more than the percentage increase in the consumer prices index during the same period, then it must instead make an order by statutory instrument amending each relief allowance amount relating to agricultural property by the percentage increase in the value of agricultural land.”
Amendment 6, page 461, line 2, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 7, page 461, line 3, leave out sub-paragraphs (2) and (3)
See explanatory statement for Amendment 3.
Amendment 34, page 461, line 3, leave out sub-paragraphs (2) to (4)
See explanatory statement for Amendment 31.
Amendment 8, page 461, line 17, leave out “sub-paragraph (3) will not apply” and insert
“the transfer will prove to be an exempt transfer”.
See explanatory statement for Amendment 3.
Amendment 9, page 461, line 21, leave out from “paragraph” to end of paragraph 17(5)(b) and insert
“comes into force on 1 March 2027”
See explanatory statement for Amendment 3.
Amendment 35, page 461, line 21, leave out from “paragraph” to end of paragraph 17(5)(b) and insert
“comes into force on 6 April 2026”
See explanatory statement for Amendment 31.
Amendment 10, page 461, line 28, leave out “30 October 2024” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 36, page 461, line 28, leave out “30 October 2024” and insert “6 April 2026”
See explanatory statement for Amendment 31.
Amendment 11, page 461, line 31, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 12, page 461, line 33, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 13, page 461, line 36, leave out “6 April 2026” and insert "1 March 2027”
See explanatory statement for Amendment 3.
Amendment 14, page 461, line 38, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 15, page 462, line 3, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 16, page 462, line 7, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 17, page 462, line 15, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 18, page 462, line 19, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 19, page 462, line 30, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 20, page 462, line 35, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 21, page 464, line 14, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 22, page 464, line 21, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Amendment 23, page 464, line 27, leave out “6 April 2026” and insert “1 March 2027”
See explanatory statement for Amendment 3.
Schedule 12.
New clause 1—Section 62: application in Northern Ireland—
“(1) The Chancellor of the Exchequer must, within six months of this Act coming into force, publish an assessment of the effects of the measures in section 62 as they apply in Northern Ireland.
(2) The assessment must consider—
(a) the number of estates in Northern Ireland expected to be subject to the reduction in agricultural property relief made under this Act,
(b) the potential benefits to farmers in Northern Ireland of exempting land used for agricultural purposes from the changes to agricultural property relief made under this Act,
(c) the potential costs to the Exchequer of exempting land used for agricultural purposes from the changes to agricultural property relief made under this Act,
(d) the impact of the measures on farm succession, land retention, and the viability of agricultural businesses in Northern Ireland, including any potential implications for the resilience and security of the UK’s food supply, and
(e) any other matters that the Chancellor of Exchequer deems appropriate.
(3) In subsection (2), “land used for agricultural purposes” does not include land that falls within the Financial Conduct Authority’s definition of a land-banking investment scheme.
(4) In carrying out the assessment, the Chancellor of the Exchequer must have regard to—
(a) the average farm size and land valuation profile in Northern Ireland,
(b) the prevalence of intergenerational family farming in Northern Ireland,
(c) the interaction between agricultural property relief and devolved agricultural support schemes, and
(d) any disproportionate impact on rural communities in Northern Ireland.
(5) The assessment must be carried out following meaningful consultation with—
(a) the Department of Agriculture, Environment and Rural Affairs in Northern Ireland,
(b) representatives of farmers and land-based businesses in Northern Ireland, and
(c) such other persons as the Chancellor of the Exchequer considers appropriate.
(6) The Chancellor of the Exchequer must, within three months of publishing the assessment, lay before Parliament a statement setting out the steps the Government intends to take in response to the assessment’s findings.
(7) The Chancellor of the Exchequer must keep the operation of the measures in section 62 under review in light of the assessment and publish a further assessment within 18 months of this Act coming into force.”
New clause 6—Impact assessment of section 62 prior to implementation—
“(1) The Chancellor of the Exchequer must, within three months of the passing of this Act, lay before the House of Commons an assessment of the impact of implementation of section 62 on family-owned farms and businesses.
(2) The assessment made under subsection (1) must consider potential impacts on—
(a) business continuity,
(b) land use, and
(c) rural employment.”
New clause 7—Uprating of allowance amounts for agricultural property—
“The Chancellor of the Exchequer must, within six months of the passing of this Act, undertake and publish an assessment of the potential merits of uprating annually the relief allowance amount for agricultural property by the change in the value of agricultural land.”
New clause 17—Review of anti-forestalling provisions relating to Agricultural Property Relief—
“(1) The Treasury must conduct a review of the effects of the anti-forestalling provisions relating to Agricultural Property Relief.
(2) The review must, in particular, consider the effects of those provisions on—
(a) succession planning and intergenerational transfer of agricultural land and businesses,
(b) the viability and continuity of family-run farms,
(c) food security and domestic agricultural production,
(d) land management, environmental stewardship, and the condition of the countryside, and
(e) the availability of agricultural land for active farming.
(3) In conducting the review, the Treasury must consult such persons as it considers appropriate, including representatives of the agricultural sector.
(4) The Treasury must lay before the House of Commons a copy of the report within 12 months of the coming into force of the anti-forestalling provisions under this Act.”