Multiple shareholders and inheritance tax changes

The changes in inheritance tax allowance for business property relief opens up potential restructuring options for shareholdings, but not without risk, explains James Woods-Davison, senior associate at Boodle Hatfield

 

The government announced in December 2025 the allowance for business property relief (BPR) would be increased from £1m to £2.5m. Given that this allowance is available to both individuals and trustees, there is a renewed incentive to consider the extent to which shareholdings in businesses can be restructured in favour of multiple shareholdings in order to take full advantage of the £2.5m allowance for inheritance tax (IHT) purposes.

Whereas saving IHT might be integral to preserving the long-term viability of a business, any decision to restructure into multiple shareholdings ought to be considered holistically in relation to the stability of the business.

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