In this article, our Legal Content Manager, Krithika Sahi, explores  what the 2026 inheritance tax changes mean in practice for Private Client Solicitors and Will Writers, and where existing Wills may need closer review.

 

The 2026/27 tax year is now underway, bringing a number of important inheritance tax (IHT) changes into effect.

 

While many of these developments have been signposted over time, their implementation marks a clear shift in how inheritance tax should be approached in practice.

 

For Private Client Solicitors and Will Writers, the key consideration is not simply what has changed – but what those changes mean for existing Wills, long-term planning, and client understanding. 

 

 

Why inheritance tax is becoming more relevant for more clients

 

One of the most significant drivers remains unchanged: the continued freeze on the nil-rate band and residence nil-rate band. 

 

Although this is not a new policy, its impact is cumulative. 

 

As property values and asset portfolios grow, more estates are likely to move within the scope of inheritance tax – including those that may previously have been considered outside it. 

 

What this means in practice: 

• Clients may now face inheritance tax exposure where none previously existed  

• Existing Wills may not reflect the current value of the estate  

• Earlier advice may no longer produce the intended outcomes  

For many clients, this shift will not be immediately visible, making proactive review increasingly important. 

 

 

Business Property Relief and Agricultural Property Relief: what has changed in April 2026

 

From April 2026, caps on Business Property Relief (BPR) and Agricultural Property Relief (APR) are now in place. 

 

100% relief is now capped at £2.5 million per individual, with qualifying assets above this threshold generally eligible for 50% relief.

 

For spouses and civil partners, this allowance may be transferable, meaning up to £5 million of qualifying assets could benefit from full relief where structured appropriately. 

 

These reliefs have historically played a central role in enabling the transfer of business and agricultural assets with reduced or no inheritance tax liability. The introduction of limits represents a meaningful change to that position. 

 

Key considerations for practitioners: 

• Some estates may move from full relief to partial exposure  

• Existing Wills and succession structures may no longer be aligned with intended outcomes  

• Business owners and landholders may need to revisit planning assumptions  

While the full impact will depend on individual circumstances, the direction is clear: greater scrutiny and more tailored planning will be required. 

 

 

International estates and UK inheritance tax: increasing complexity

 

For clients with international connections, inheritance tax planning is becoming more complex. 

 

The ongoing move towards a residence-based system means that UK inheritance tax may apply more widely than expected, depending on an individual’s residency history. 

 

Areas requiring careful review include: 

• UK residency status over time  

• The location and structure of assets  

• How Wills interact across multiple jurisdictions  

This is an area where assumptions can easily become outdated, particularly for globally mobile clients. 

 

 

How pensions are influencing estate planning now

 

Although changes to the inheritance tax treatment of pensions are not due until April 2027, they are already shaping planning discussions. 

 

Pensions have traditionally been treated separately from the estate for inheritance tax purposes. That distinction is becoming less clear, prompting a more integrated approach. 

 

Practitioners should be considering: 

• How pensions fit within the overall estate strategy  

• Whether beneficiary nominations align with the client’s Will  

• How different asset classes interact on death  

This reflects a broader trend: estate planning is becoming more interconnected, rather than segmented. 

 

 

Why reviewing existing Wills is now critical

 

A consistent theme across these changes is the growing risk of outdated planning. 

 

In many cases, the issue is not that clients have failed to plan but that their planning has not been revisited as circumstances and legislation have evolved. 

 

Key risk areas include: 

• Wills drafted under previous tax assumptions  

• Reliance on reliefs that may now be limited  

• Misalignment between different parts of the estate (e.g. pensions and Wills)  

Regular review is becoming an essential part of good practice, rather than a periodic exercise. 

 

 

A shift towards ongoing estate planning

 

Taken together, the inheritance tax changes introduced in 2026 reinforce a broader shift in the profession. 

 

Estate planning is moving away from a one-off transaction and towards an ongoing advisory process. 

 

For Private Client Solicitors and Will Writers, this means: 

• Engaging clients more regularly  

• Providing clearer visibility of potential outcomes  

• Supporting more informed decision-making over time  

Importantly, this is not about increasing complexity for its own sake – but about ensuring that planning remains accurate, relevant, and aligned with client intentions. 

 

 

Supporting better client outcomes

 

As inheritance tax becomes more relevant to a wider range of clients, the role of the practitioner becomes increasingly important. 

 

Clear communication, regular review, and a structured approach to planning will be key to helping clients navigate these changes with confidence. 

 

Platforms like Arken are being developed to support this approach – enabling Private Client Solicitors and Will Writers to build a clearer picture of a client’s estate, model potential outcomes, and communicate advice in a more accessible and transparent way.