Request for Proposals: Understanding the Impact of Business Property Relief (BPR) Reforms on UK Family Businesses
Introduction
The Family Business Research Foundation is inviting proposals for new research to understand how the changes to Business Property Relief (BPR) announced in the October 2024 Budget affect family businesses in the UK. This page provides information about the proposed project, its background, together with guidance on how you can apply and what to include in your proposal.
1. Background and Policy Context
1.1 Overview of Business Property Relief
Business Property Relief (BPR) reduces the value of qualifying business assets for Inheritance Tax (IHT) purposes. Established in 1976, BPR aims to prevent the forced sale of businesses to pay tax liabilities upon the death of owners. Currently, it applies to assets such as unlisted shares and business property, providing relief at rates of 50% or 100% (Policy Points, 2024). In 2021/22, BPR benefited 4,170 estates at a cost of approximately £1.1 billion, predominantly claimed by estates valued above £1 million (House of Commons, 2025).
1.2 Government Reforms to BPR
The Autumn Budget 2024 announced reforms to BPR effective from April 2026:
Introduction of a cap of £1 million on combined agricultural and business assets eligible for 100% relief, with 50% relief applicable thereafter.
Reduction to 50% relief for all previously eligible unlisted shares (HM Treasury, 2024).
These changes are forecasted by the Office for Budget Responsibility (OBR) to generate additional revenue of approximately £0.5 billion annually from 2027/28, although projections are highly uncertain due to potential taxpayer behavioural responses (changes in taxpayer behaviour due to policy adjustments) (OBR, 2024).
1.3 Stakeholder Views on the BPR Reforms
Having outlined the reforms, it is essential to examine how stakeholders perceive their potential impacts. FBUK has raised significant concerns that the reforms will negatively impact family businesses by disrupting succession planning, reducing long-term investment, and limiting employment growth. Independent research commissioned by FBUK (CBI Economics, 2025) forecasts a potential £14.8 billion reduction in economic output and net fiscal losses of around £1.9 billion between 2026 and 2030 due to diminished economic activity.
Conversely, organisations including the Institute for Fiscal Studies (IFS) and Resolution Foundation argue that BPR disproportionately benefits wealthier estates and facilitates tax avoidance. The IFS has specifically proposed capping or abolishing the relief to increase tax revenue and equity (Advani & Sturrock, 2023; IFS, 2024). Moreover, the OECD has highlighted limited evidence of broad economic benefits from such tax reliefs, suggesting instead that they may negatively influence productivity by reducing the incentives for effective business management (OECD, 2021).
2. About the Study
This study aims to examine the behavioural and strategic responses of family businesses to BPR reforms, informing both policy and business decision-making.
As part of a wider programme of work seeking to assess the impact of the reforms to BPR on family businesses in the UK, the FBRF seeks to commission new qualitative research to understand how the reforms have affected family businesses and business families in before and after April 2026, when the BPR reforms will come into effect.
The project will build on the Supporting Succession? white paper (FBRF/Policy Points, 2024) and surveys/economic modelling by CBI Economics/FBUK (2024, 2025) and will contribute to the evidence base needed to evaluate the impact of these tax policy reforms.
This research seeks to understand how family business responses to the BPR reforms with the goal of informing policy and practice. For example,
How are family businesses and business-owning families changing their behaviour, decision-making, strategy, and expectations in anticipation of the reforms coming into effect?
What impact will the implementation of the reforms in April 2026 have on family businesses - for example, on their succession planning, ownership model/structure, strategy, investment decisions, ownership structures, and workforce decisions?
Identify differences in responses and how businesses adapt to the reforms, for example, across business sizes and sectors.
3. Research Strategy and Methodology
The research strategy for the project will include three main elements:
Longitudinal Case Studies:
Conduct qualitative research with a small sample of family businesses over the reform implementation period (before and after April 2026). The case study research will include qualitative interviews with business owners, members of business families, senior employees/managers in family businesses, to understand how they have responded to be and have been/expect to be affected by to the BPR reforms. We would like to track changes in business behaviour, decision-making, ownership model/structure, strategy, and outcomes over time to understand how family firms/business firms are adjusting to the new tax environment; for example, in areas such as succession planning, investment, workforce, or asset allocation before and after the implementation of the reforms. Data collected will be systematically analysed using qualitative data analysis methods to identify common themes, key insights, and to explore differences in responses based on business/family characteristics. See Molloy et al. (2002) for a discussion of the longitudinal case study approach in evaluation research.
Policy research - expert stakeholder Interviews:
Engage a broad range of stakeholders—including policymakers, economists, tax specialists, family business professionals, membership bodies and networks, business organisations, research institutes and centres —through semi-structured interviews to capture diverse insights on the anticipated and observed impacts of the changes to BPR on family businesses and business owning families. Data collected will be systematically thematically analysed.
Gather and review relevant evidence:
Gather, review, and synthesise evidence and data relating to BPR and business tax reliefs to contextualise the study's findings and enhance policy recommendations. This includes identifying key statistical sources and reviewing any relevant evidence on tax reliefs and how they affect family-owned businesses. This encompasses international evidence on tax reliefs and IHT policies, and their impact on business behaviour; evidence from studies by FBUK/CBI Economics and other stakeholders to understand business responses to BPR reforms; government statistical data relating to BPR (HMRC, ONS, OBR, HM Treasury).
4. Deliverables
Interim Report: Mid-point research findings to facilitate stakeholder engagement.
Final Comprehensive Report: A detailed document summarising findings, implications for family businesses, and policy recommendations.
Policy Recommendations Summary: Clear and actionable recommendations for policymakers and business leaders.
Conference Presentation/Panel Discussion Event: Either a conference presentation or participation in a panel discussion to share key findings and promote dialogue among policymakers, academics, and practitioners.
5. Process of Applying
Interested research teams, consultancies, and institutions are invited to submit proposals. The deadline for submissions is Friday 8th August 2025, and proposals should be emailed to info@fbrf.org.uk.
Applicants should ensure that their proposals align with the objectives and scope outlined in this document.
Proposals should be a maximum of 1,000 words (excluding CVs and references) and must include:
Research Questions and Objectives: A clear explanation of how the study will address the specified research questions.
Methodology: A detailed description of research design, methods, and data sources. Please note that the FBRF adopts the European definition of family business.
Project Team: Roles, responsibilities, and expertise of team members. CVs of members of the project team should be attached to your proposal, including details of any qualifications and experience relevant to the project. Applicants should indicate who will take the lead on the project.
Timeline and Milestones: Key deliverables and expected completion dates.
Budget: A breakdown of costs, ensuring value for money. Note that the FBRF is a charity and therefore does not cover indirect costs.
Dissemination Plan: Strategies for maximizing policy and stakeholder engagement.
Proposals will be evaluated based on the following criteria:
Relevance and Feasibility: Alignment with research objectives and practical feasibility.
Methodological Rigour: Robustness of the proposed research approach.
Team Expertise: Experience in economic, policy, and tax research.
Value for Money: Cost-effectiveness of the proposed budget.
Impact and Dissemination Strategy: Potential to inform policy and benefit stakeholders.
6. About the Family Business Research Foundation
The FBRF is a registered charity since 2009 and was established to foster greater understanding of family firms and their contributions to the UK economy and society. The FBRF’s mission is to provide evidence-based research and practical guidance to support family businesses and inform policymaking. Click here for more information about the charity.
For queries related to this RFP, please contact Dr. Martin Kemp at info@fbrf.org.uk
References:
Advani, A. and Sturrock, D., 2023. Reforming Inheritance Tax. Institute for Fiscal Studies. Available at: https://ifs.org.uk/sites/default/files/2023-09/Reforming-inheritance-tax-1.pdf [Accessed 25 June 2025].
CBI Economics, 2025. Taxing Futures: Economic and Fiscal Implications of BPR & APR for UK Family Businesses and Farms. Family Business UK. Available at: https://familybusinessuk.org/wp-content/uploads/2025/05/FBUK-Taxing-Futures-Report-June-2025.pdf [Accessed 25 June 2025].
European Commission (2009) Overview of Family-Business-Relevant Issues: Research, Networks, Policy Measures and Existing Studies. Directorate-General for Enterprise and Industry. Available at: https://ec.europa.eu/docsroom/documents/10388/attachments/1/translations/en/renditions/native [Accessed 18 June 2025].
House of Commons, 2025. Changes to Agricultural and Business Property Reliefs for Inheritance Tax. Commons Library Research Briefing CBP-10181. 29th May 2025. Available at: https://commonslibrary.parliament.uk/research-briefings/cbp-10181/ [Accessed 25 June 2025].
HM Treasury, 2024. Autumn Budget 2024. Available at: https://www.gov.uk/government/publications/autumn-budget-2024 [Accessed 25 June 2025].
Institute for Fiscal Studies (IFS), 2024. Raising Revenue from Closing Inheritance Tax Loopholes. Available at: https://ifs.org.uk/articles/raising-revenue-closing-inheritance-tax-loopholes [Accessed 25 June 2025].
Molloy, D., Woodfield, K., Bacon, J., Longhurst, N. and Newburn, T., 2002. Longitudinal Qualitative Research Approaches in Evaluation Studies [online]. London: HMSO. Available at: https://timescapes-archive.leeds.ac.uk/wp-content/uploads/sites/47/2021/04/Molloy-et-al-2002-WP7.pdf [Accessed 25 June 2025].
OECD, 2021. Inheritance Taxation in OECD Countries. OECD Tax Policy Studies, No. 28. OECD Publishing, Paris. Available at: https://doi.org/10.1787/e2879a7d-en [Accessed 25 June 2025].
Office for Budget Responsibility (OBR), 2024. Economic and Fiscal Outlook – October 2024. Available at: https://obr.uk/efo/economic-and-fiscal-outlook-october-2024/ [Accessed 25 June 2025].
Policy Points, 2024. Supporting Succession: Policy Analysis of BPR. Family Business Research Foundation. Available at: https://www.fbrf.org.uk/news/new-white-paper-on-bpr [Accessed 25 June 2025].
Resolution Foundation, 2024. More, More, More – Putting the 2024 Autumn Budget in Context. Available at: https://www.resolutionfoundation.org/app/uploads/2024/10/More-more-more-Budget-2024.pdf [Accessed 25 June 2025].