The 2026 Turning Point for Farming Families The April 2026 reforms to Agricultural Property Relief (APR) and Business Property Relief (BPR) mark a watershed moment for UK farming families. For decades, these reliefs shielded land and businesses from crippling inheritance tax, providing families with the space to hand farms down intact. With tighter caps and stricter rules, that safety net is thinning. Yet this shift need not spell decline. In fact, it can ignite renewal. Farming families who respond with foresight, structure, and unity can reshape agriculture on their own terms, safeguarding their farms and building stronger, more resilient institutions for future generations.
Rethinking Succession in the New Tax Landscape Inheritance tax reform rarely captures headlines outside professional circles, yet the April 2026 changes to APR and BPR will be felt in every corner of the countryside. Once, a farm worth millions could pass to the next generation with little tax friction. Soon, families may face seven-figure liabilities simply for continuing what their parents built. These changes arrive against a backdrop of squeezed profitability, volatile food supply chains, and policymaking often favouring urban perspectives. The narrative is forming: family farms will shrink, consolidate under corporate buyers, or vanish. But this is not the only path. Tax reform, though painful, can be a catalyst. It forces a reckoning with outdated thinking about ownership, succession, and farming. If handled wisely, change can be the lever for renewal. Through modern structures such as the Mural Crown Self-Administered Family Office (SAFO), combined with stewardship vehicles like Employee Foundations, families can protect inheritance positions, reinvest more of their income, and even join forces with neighbours to compete with multinationals. Case studies already show the potential: some families are redesigning succession with Mural Crown SAFOs, while others are forming regional food alliances that bypass supermarkets entirely. The question is not whether family farming will survive. The question is whether it will adapt and, in doing so, become more enduring.
From IHT Burden to Institutional Legacy: Mural Crown SAFOs in Practice For many years, APR and BPR were the keystone of farm succession. They allowed land and businesses to move down generations with little or no inheritance tax. That certainty is now gone. From April 2026, the rules change:
Each individual receives £1m of combined APR/BPR at 100% relief.
Amounts above that receive only 50% relief, leaving half of the excess exposed to 40% inheritance tax.
Couples can each use their £1m allowance if they own assets separately, but the relief is not transferable.
Example: The £10m family farm Imagine the Carter family with a £10m mixed farm. Under the new rules:
£2m (across both parents’ £1m allowances) is fully relieved.
The remaining £8m qualifies for only 50% relief. Half of that (£4m) is taxable at 40%.
Total liability: £1.6m. (This is after personal tax, so could be £2.4m+ gross to the farm)
That liability translates into forced sales, rushed borrowing, or disputes over who shoulders the burden. What was once a safe handover is now a high-risk event.
Why Traditional Planning Fails And What to Do Instead
Most farm wills were written for a different world. Passing everything to the spouse's deferred tax, but now it risks wasting allowances. Traditional discretionary trusts can help, yet they drag their own costs: a 20% entry charge above £325,000 and a 6% ten-year charge on trust value. For a £10m farm, that means £2m upfront and £0.6m every decade.
Three common weak points now show:
Wills that defer everything: spousal exemption delays tax but wastes a £1m allowance if assets pass outright.
Fragmented ownership: scattered parcels across partnerships, companies, and individuals make relief calculations messy and reduce efficiency.
No liquidity plan: large tax bills land at the wrong time, forcing sales of productive acres or emergency debt.
The old “wait and see” approach is no longer safe. Families need coherent ownership, transparent governance, and modern corporate tools.
A New Model for Renewal: The SAFO and Employee Foundation Framework
The Mural Crown SAFO is not a financial product but a structural framework. It converts the family farm into a bespoke holding company supported by a fiduciary, using alphabet shares to separate control from value.
Key share classes:
Voting shares: A nominal block, often £100 in total, retaining decision power.
Freezer shares: Issued in exchange for today’s farm business, fixing the current value in the estate.
Growth shares: Low value at creation, capturing all future appreciation, often placed into family trusts.
Dividend shares: Flexible rights to distribute income tax-efficiently.
Case Study: The Carter Family Facing a potential £1.6m IHT bill, the Carters restructure:
Their £5m farm business is incorporated and exchanged for £5m of Freezer shares plus Voting shares worth £100.
Growth shares are created and placed into a discretionary trust for their children, capturing all future appreciation above £5m.
Dividend shares allow income to be split across family members in different tax bands.
The parents retain control but cap their exposure. The next generation gains growth outside the estate.
An Employee Foundation, structured as an EBT, avoids both. Freezer shares are gifted to the Foundation, removing value from the estate with no entry or periodic charges. Growth shares remain in family trusts, and Voting shares stay with the parents.
Case Study: The Hughes Farming Group The Hughes family run a £12m dairy enterprise:
They receive £12m of Freezer shares and 1,000 Voting shares.
They gift £10m of Freezer shares into an Employee Foundation, avoiding the £2m entry charge and £0.6m ten-year charges of a discretionary trust.
Growth shares are gifted into multiple family trusts, ensuring future appreciation accrues outside the estate.
The Foundation receives dividends on its Freezer shares for housing, training, and workforce bonuses. Employees become long-term stewards, strengthening continuity.
The alternative is bleak:
A discretionary trust drains £2m upfront and £0.6m every decade.
Leaving £10m exposed creates a £2m IHT bill, effectively a £200k annual burden if funded over 10 years. (Which can be £350k+ gross to the farm, as personal income is charged to the heirs paying the £200k)
Neither route helps the farm grow.
By contrast, the Mural Crown SAFO + Foundation model creates a £10m internal fund to support productivity and people. That capital can fuel:
Training for new machinery to reduce costs.
Education on regenerative practices to secure long-term soil health.
Employee Bonuses to increase productivity.
Combined with corporate tax reliefs (19–25% corporation tax, R&D credits, capital allowances), this framework keeps more money inside the farm business. SPVs for land parcels add flexibility each plot can be managed, sold, or transferred without disrupting the whole.
When multiple Mural Crown SAFO-structured families align, their collective power grows. Regional Food Alliances become the modern co-operative:
Bulk-buy inputs at scale.
Negotiate contracts with institutions like schools and hospitals.
Create regional processing hubs for milk, grain, and vegetables.
Launch consumer-direct brands that bypass supermarkets.
The Hughes family used their Mural Crown SAFO as a base to form an alliance with four neighbours. By coordinating purchasing and direct supply, they lifted margins by 15% while preserving independence.
Without planning, a £10m farm bleeds value: £2m upfront in a trust, £0.6m per decade, or £200k a year in IHT exposure. With a Mural Crown SAFO and Employee Foundation, that same £10m becomes an internal fund for employees and reinvestment.
This is more than a tax strategy. It transforms farms from fragile businesses into resilient institutions:
Control stays with the parents.
Frozen value moves into the Foundation.
Growth passes to the next generation free of IHT.
Employees become invested partners in success.
When families then co-operate regionally, they reclaim supply chains, bypass supermarkets, and strengthen communities.
