Business Property Relief policy narratives: how competing values shape the debate
By Martin Kemp, Family Business Research Foundation
The reforms to Business Property Relief (BPR) and Agricultural Property Relief (APR) announced in the Autumn Budget 2024 will introduce a single 100% relief allowance for the combined value of qualifying APR and BPR property, and reduce the rate of relief for ‘not listed’ shares admitted to trading on recognised stock exchanges, with implementation scheduled from 6 April 2026 (HM Treasury, 2024; HMRC, 2026). The period running up to the Autumn Budget 2024 and the ensuing policy debate through 2025, including Budget 2025 (HM Treasury, 2025a), saw significant debate about BPR and APR in Parliament and in the media, and among politicians, think tanks, academics, business organisations, advisory and industry bodies (Kemp, 2025a).
The Family Business Research Foundation (FBRF) report Business Property Relief and Family Firms in the UK: From Relief to Reform uses narrative policy analysis to make sense of and interpret how this debate has unfolded. Narrative policy analysis examines how different actors frame a policy problem, what outcomes they prioritise, and how they construct persuasive storylines in support of particular policy positions (Roe, 1992, 1994, 2024). The purpose of this article is to identify the policy narratives running through this debate, and the metanarrative that underpins them, and to understand why consensus has been difficult to achieve.
BPR policy narratives
The report identifies five policy narratives that have structured the debate about BPR and APR following the Autumn Budget 2024 announcement and through 2025. Each of these narratives can be analysed into their common narrative components (setting, characters, plot and moral). References to characters as heroes, villains or victims are used as analytic labels describing how a narrative positions different actors. For a more detailed account of the evidence and source material underpinning each narrative, please refer to the full report. The five policy narratives identified in the analysis include the following:
1. Continuity and community narrative
The continuity and community narrative frames BPR as critical to preserving family-owned businesses and their contribution to local economies and communities. In this storyline, family-business owners are cast as heroes, while the tax authorities and fiscal policymakers are cast as villains seeking to extract tax, and workers or communities are portrayed as potential victims if businesses are forced to sell assets or change ownership at succession. Supporters commonly draw on arguments about potential disruption to investment, employment and output – see, for example, the research by CBI Economics (CBI Economics for Family Business UK, 2025; Kemp, 2025a). The moral here emphasises maintaining BPR in full or consulting extensively before reform, to protect continuity, jobs and investment.
2. Fairness and equity narrative
This narrative positions BPR and APR as tax reliefs that produce unequal outcomes between estates with similar overall wealth, and that disproportionately benefit a wealthy minority. In this storyline, wealthy estates and advisers are cast as villains, while ordinary taxpayers and public services are cast as victims. The moral is usually that BPR and APR should be capped or curtailed so that inheritance tax (IHT) liabilities depend less on asset type and more on overall wealth, with additional revenue to support public services.
3. Fiscal responsibility narrative
This narrative emphasises the need to raise revenue to fund public services and manage fiscal pressures. It is most closely associated with the Government discourse on IHT reform which has framed the changes as targeted at a relatively small group of high-value estates, together with claims that the wider economic effects are likely to be limited. The moral is to implement the cap on 100% relief as planned, to strengthen fiscal sustainability and reinforce the principle that those with greater wealth contribute more to public goods.
4. Simplification and efficiency narrative
This narrative highlights the complexity of IHT – the multiple reliefs and exemptions create distortions, administrative burdens and opportunities for avoidance. In this storyline, tax reformers and policy analysts are cast as heroes seeking a simpler, more consistent and coherent system. The reliefs themselves, and the tax planning industry that exploits such complexity, are cast as villains. The moral is to simplify IHT by rationalising reliefs, aligning the treatment of different asset classes and reducing scope for avoidance.
5. Competitiveness and investment narrative
The fifth and final policy narrative identified focuses on the UK’s competitiveness and the importance of fostering entrepreneurship and long-term investment to stimulate economic growth. It argues that predictable tax rules help to support investment planning and that uncertainty, instability or tax changes that are perceived by some to be punitive may undermine the UK’s attractiveness as a place to invest and do business. In this storyline, family firms are typically cast as heroes, while unpredictable tax policy is cast as the villain. The moral is to maintain stable and predictable rules, and to consult extensively with businesses before further reforms.
The metanarrative: a clash of values
A metanarrative runs through this policy debate and underpins these five policy narratives: the tension between fairness and continuity, and between fiscal responsibility and competitiveness. The recent debate about BPR is not just about facts and evidence, but different views about the policy goals and values that should carry most weight. This helps to explain why the debates about IHT in the UK keep recurring and why consensus has been elusive.
Policy developments since Budget 2025
Since Budget 2025 (November 2025), the UK Government has made two further changes to the planned reforms, both relating to the 100% relief allowance due to apply from April 2026. These changes are summarised in the FBRF commentary on Budget 2025 and the January 2026 update (Kemp, 2025b, 2026). The Office for Budget Responsibility (OBR) has also published supplementary material on the costing of the reforms (OBR, 2025).
The November 2025 Budget confirmed that any unused part of the 100% relief allowance will be transferable between spouses and civil partners (HM Treasury, 2025a). This was followed on 23 December 2025 by the Government announcement that the threshold at which the 100% rate of relief applies will increase from £1 million to £2.5 million. Qualifying assets above that threshold remain eligible for 50% relief (HM Treasury et al., 2025; HMRC, 2026). A Written Ministerial Statement confirmed that transferability continues to apply alongside the higher £2.5 million allowance (UK Parliament, 2026).
It should be noted that the change announced in December does not remove other elements of the BPR and APR reform package already announced. In particular, HMRC’s latest policy paper on BPR and APR confirms the planned reduction in the rate of BPR from 100% to 50% for not listed shares and the extension of the option to pay inheritance tax in equal annual interest-free instalments over 10 years to eligible property (HMRC, 2026).
HMRC’s static estimates of the number of estates expected to pay more inheritance tax have been revised downward as the policy design has changed. The latest House of Commons Library briefing on the reforms reports a reduction in the overall number of estates expected to pay more IHT in 2026-27 compared with earlier estimates, and a reduction in the estimate for estates containing a BPR claim only (Masala, Keep and Seely, 2026).
Conclusion
The narrative analysis of the policy discourse on BPR reveals a set of competing policy narratives and a clash of values underpinning this debate. Understanding these policy narratives does not resolve empirical disputes about BPR, but it can help to clarify why different actors in this debate prioritise different outcomes and why disagreement about tax policies persists.
For the full analysis and supporting evidence, please refer to the full report, Business Property Relief and Family Firms in the UK: From Relief to Reform
References
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HM Revenue & Customs (HMRC) (2026) Agricultural property relief and business property relief changes (policy paper), updated 9 January 2026. Available at: https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes (Accessed: 17 January 2026).
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