Concerns Mount Over Planning Disruption and Piecemeal Legislative Changes

Irwin Mitchell’s Private Client Advisory team is calling on the government to provide urgent clarity around proposed changes to inheritance tax (IHT) rules, amid growing concern that the current uncertainty could foster poor planning behaviours and undermine long-term succession strategies.

Reports suggest the Treasury is considering a lifetime cap on inheritance tax-free lifetime gifting and changes to taper relief—despite previous efforts to encourage lifetime giving – alongside a possible capital gains tax rate rise towards parity with income tax.

According to experts at Irwin Mitchell, these proposals, if introduced without clear guidance, risk derailing carefully considered succession plans, particularly for business and farm owners preparing for the next stage of Agricultural Property Relief (APR) and Business Property Relief (BPR) reforms in April 2026.

Expert Opinion

“The period from now until April should be a time for thoughtful, strategic succession planning. Instead, speculation and lack of clarity could prompt knee-jerk reactions, which could have long-term consequences for families and businesses.” Rose Macfarlane, Partner at Irwin Mitchell 

The firm warns that layering new proposals on top of existing draft legislation—still under consultation following last October’s announcements—creates a piecemeal and potentially retrospective effect. This is particularly problematic for those who have already acted, or are planning to, in good faith based on previous guidance.

Expert Opinion

“If these reforms are introduced without proper consultation or transitional protections, they could render many gifting strategies ineffective. Clients making substantial gifts this autumn may find themselves caught out if a lifetime allowance is imposed retrospectively, or find considered succession plans upended by an announcement at the Autumn Statement.”

“It is vital the government provides clear, timely communication to prevent further disruption and ensure families can plan with confidence.”
Rose Macfarlane 

Irwin Mitchell also warns that the government's failure to shut down speculation around these reforms could itself be fiscally significant. In the absence of clear guidance, many individuals may rush to make gifts before any changes are introduced—potentially reducing the intended capital gains tax take.