Author: Glenn

Despite intense lobbying by the farming community, the proposed reduction in IHT Business and Agricultural Property reliefs are included in the draft Finance Bill 2025-26.

On 21 July 2025, the government published draft legislation for Finance Bill 2025-26. The consultation period for the draft legislation is open until 15 September 2025. This comes at a time when the government has seen borrowing in June surge to the second highest level on record and placing further pressure on public finances and increasing the urgency for tax reforms.

The legislation includes confirmation of a significant overhaul of Inheritance Tax (IHT) reliefs that were first announced in the Autumn Budget 2024. These measures faced criticism over their potential impact on small farms and rural communities. However, with the publication of the Finance Bill, these measures now look set to come into effect from 6 April 2026.

The changes will see the introduction of a new £1 million allowance that will apply to the combined value of property in an estate qualifying for 100% business property relief or 100% agricultural property relief. This means that the existing 100% rate of IHT relief will only apply to the combined value of property in an estate qualifying for 100% business property relief or 100% agricultural property relief. The rate of IHT relief will be reduced to 50% for the value of any qualifying assets over £1 million. This means that any assets receiving 50% relief will be effectively taxed at 20% IHT (the full rate being 40%).

This change applies per individual, meaning married couples could potentially pass on up to £3 million tax-free between them (when combined with nil-rate bands).

The government has also confirmed they will reduce the rate of business property relief available from 100% to 50% in all circumstances for shares designated as “not listed” on the markets of recognised stock exchanges, such as AIM. The existing rate of relief will continue at 50% where it is currently this rate and will also not be affected by the new allowance.

It was also announced that the option to pay IHT by equal annual instalments over 10 years interest-free will be extended to all qualifying property which is eligible for agricultural property relief or business property relief.

Who values goodwill when a business is sold? HMRC's Shares and Assets Valuation team takes the lead.

Whether the goodwill belongs to a sole trader, partnership or limited company, HMRC’s SAV team will either accept the submitted valuation, give their own open market estimate, or state they need more information.

For non-corporate goodwill, the SAV team have the following options for valuing goodwill:

• Accepting the valuation
• Providing an opinion of Open Market Value if the claim appears under or overvalued
• Stating that insufficient information is available to form a view

Corporate goodwill valuations are usually submitted directly to SAV as informal or formal requests. When Trade Related Property is involved, the SAV team will liaise with the Valuation Office Agency.

These are the key issues the SAV team will look at when valuing goodwill:

• the full sale and purchase documentation relating to the transfer of both tangible and intangible assets;
• succession arrangements;
• the valuation approach used – e.g. capitalisation of profits, super profits or a trade specific method;
• the activities of the business and role of the owners within it;
• the financial statements/accounts (including the detailed trading and profit and loss account) for the 3 years before valuation;
• any other relevant financial information;
• appropriate yield and multiples of comparable companies and sectors;
• the commercial and economic background at valuation date;
• how the personal goodwill of the owner has been reflected in the valuation; and
• any other relevant factors.

Open market value must exclude any assumptions about a "special purchaser" unless industry norms support synergy-based premiums.

Married couples can pass on up to £1 million tax-free if they plan their estates carefully.

The Inheritance Tax  (IHT) nil-rate band is currently £325,000. This means there is normally no IHT to pay if an estate is valued below this threshold. This amount can be higher if you leave everything above the £325,000 threshold to your spouse, civil partner, a charity or a community amateur sports club.

In addition, there is an IHT residence nil rate band (RNRB) of £175,000. This is a transferable allowance for married couples and civil partners (per person) when their main residence is passed down to a direct descendent such as children or grandchildren after their death. The allowance is available to the deceased person’s children or grandchildren.

Any unused portion of the RNRB can be transferred to a surviving spouse or partner. The RNRB is in addition to the £325,000 nil-rate band. The allowance is available to the deceased person's children or grandchildren. Taken together with the current IHT limit of £325,000 this means that married couples and civil partners can pass on property worth up to £1 million (£325,000 x 2 plus £175,000 x 2) free of IHT to their direct descendants. 

The transfer does not happen automatically and must be claimed from HMRC when the second spouse or civil partner dies. This is usually done by the executor making a claim to transfer the unused RNRB from the estate of the spouse or civil partner that died first.

There is a tapering of the RNRB for estates worth more than £2 million even where the family home is left to direct descendants. The additional threshold will be reduced by £1 for every £2 that the estate is worth more than the £2 million taper threshold. This can result in the full amount of the RNRB being tapered away. 

VAT relief is available on goods and services for people with long-term illnesses or disabilities. 

There are special VAT reliefs available for certain people living with disabilities or long-term illnesses. These reliefs are generally available on certain products and services designed specifically for their personal or domestic use. This VAT relief covers not only the product itself but also installation, repairs, maintenance as well as related spare parts and accessories.

Eligible items typically include adjustable beds, stair lifts, wheelchairs, medical aids, low vision aids (excluding glasses or contact lenses) and home building works such as ramps, widened doorways or lifts. Motor vehicles purchased or leased through the Motability scheme may also qualify.

To benefit from this relief, the individual must meet HMRC’s criteria which usually covers those with a long-term physical or mental condition affecting daily life, chronic illnesses such as diabetes or terminal conditions. Age criteria alone, or temporary disabilities, do not qualify.

Buyers must provide a written declaration confirming their eligibility. Most suppliers will provide a standard form for this purpose.

For imported items, qualifying goods for personal use can benefit from VAT relief if they are properly declared.

Local councils may also offer support or funding for necessary home adaptations, helping ensure greater independence and quality of life for disabled individuals.

A recent ruling affirms that an employer is directly liable for the unauthorised disclosure of an employee's private information. An employee worked at a JD Wetherspoon pub for approximately eighteen months, during which time she provided her contact details, including her mother's mobile number as an "emergency contact phone number". These details were kept in her personnel file, conspicuously marked "Strictly Private and Confidential," and locked in a filing cabinet in the manager's office. She ceased working at the pub before Christmas 2018, and her details were properly retained by the defendant.

Throughout 2018, the claimant endured severe abuse from her then-partner, who was arrested in the autumn and held on remand for serious violence and harassment offences. Due to a history of abuse and her desire to avoid further contact with him, she changed her mobile phone number, rendering the number on file obsolete, although her mother's mobile number remained active.

On Christmas Day 2018, while on remand, her ex-partner obtained a mobile phone and called the Wetherspoons pub, falsely identifying himself as a police officer and claiming an urgent need to contact the claimant. A staff member who knew the claimant consulted with the manager, who then accessed the claimant's confidential personnel file, transcribed her mother's mobile number, and instructed the staff member to provide it to the caller.  

The ex-partner then called the claimant's mother, who was out at a Christmas lunch with her family, including the claimant. Again impersonating a police officer, he persuaded the mother of his urgent need to speak to the claimant, and the phone was passed to her, whereupon she was verbally abused and threatened. Not only had the abusive relationship and her fear of contact been disclosed to the manager on several occasions, but Wetherspoons was aware that "pretexting" is a known threat and that their staff was trained concerning such threats.  

The claimant successfully sought damages pertaining to the misuse of private information and breach of confidence, although claims of further breaches under the Data Protection Act (DPA) 2018 and the General Data Protection Regulation (GDPR) 2018, while initially dismissed, were later upheld by the High Court.

Here, there is a clear distinction drawn between a failure to keep data secure online and an active disclosure of data by the employer's staff. Employers must not only have policies in place but also ensure that they are understood and followed in practice. Such training must be robust and regularly reinforced to avoid being found vicariously liable. It is simply insufficient to have a "Strictly Private and Confidential" label or issue a training manual. An employee's emergency contact details, even if they are those of a relative, constitute private information, and employees have a reasonable expectation of privacy.