For centuries, land ownership has been the cornerstone of British wealth.
Today, in the age of inflation, political censorship and transfer of tax policies, UK farmland is once again in a prevalent state, not just as a legacy asset, but a strategic, tax-effective investment (HNWIS) for high net worth individuals (HNWIS) and business owners seeking long-term capital protection.
However, the rules that underpin this herdsman’s advantage are threatened. As Prime Minister Rachel Reeves proposes a proposal to reform agricultural property relief (APR), it has long been a paradise of prudence passed down from generation to generation and may soon face profound changes.
The lasting appeal of the land
Farmland continues to offer a strong value proposition: scarcity, price elasticity and unparalleled tax breaks. According to Royal Chartered Surveyors (RICS), UK farmland value grew 7.3% in 2024, inspired by investor demand, food security issues and the monetization of natural capital offset by carbon credit and biodiversity.
“Farmland provides heritage and leverage,” said Henry Pemberton, a land consultant for Savills. “From a tax and wealth planning perspective, it has few competitors.”
Tax Structure: APR, BPR and CGT Deferral
At the heart of the farmland appeal is Agricultural Property Relief (APR) and Commercial Property Relief (BPR) – a powerful tool that reduces inheritance taxes 100% when the correct structure is done.
- APR is suitable for actively cultivated or rented land for agricultural use, as long as it lasts for two years (or seven years).
- BPR can extend this protection to a mixed use or diversified legacy that generates transaction revenue, such as from holidays, or renewable energy.
- Capital gains tax (CGT) can often be delayed by shelving or deductions, further improving the real estate planning efficiency of assets.
Tech entrepreneur Sarah Allardyce purchased 88 acres in Kent after his 2020 business exit. Combining regenerative agriculture with solar and biodiversity credits, she constructed her own land investment to optimize relief.
Her strategies include:
- After two years of direct farming, APR is on her farmland.
- BPR about consulting companies operating from the property.
- The revenue from the Wildflower Offset Program was leased to the local conservation team.
“I didn’t buy land for subsidies,” she said. “But the tax break certainly sweetens the model.”
Storm Gathering: Reform Suggestions on the Table
In the July 2025 budget, Prime Minister Rachel Reeves launched a consultation on the APR’s overhaul (APR) – the Ministry of Finance said that by 2030, the Ministry of Finance could raise £1.2 billion in IHT. The proposed changes include:
- Limit APR qualifications to working farmers and exclude passive investors.
- Reassessment of relief for non-agricultural activities, including renewable energy, glitter and revival.
- APR restricting land held in a company or offshore building.
Critics argue that these reforms will punish environmental management, block new entrants, and undermine family-owned estates that rely on APR to represent intergenerational continuity.
Input, Jeremy Clarkson Effect
Jeremy Clarkson is the most vocal opponent, and his Amazon Prime Minister series Clarkson’s farm turns him into an unlikely agricultural advocate. In a recent episode, Clarkson opposed the idea that his farm could be seen as “inactive” under the new rules.
“So let me be straight,” he said. “I pay for tractors, barn roofs, seeds, diesel, I risk everything from the weather…and then the principal told me that the land wasn’t “active” enough to qualify for relief? Crazy.”
Clarkson joins forces with the National Farmers’ Union and the Rural Members’ Union to resist the proposed changes, warning them that they will erode rural resilience and stop sustainable innovation.
Case Study: Family Planning in the Countryside
Former logistics business owner Hunter-Bennett Family invested £6.5 million in 2022 in the 400-acre Suffolk heritage. Two adult children manage the estate full-time, and they receive full APR and BPR relief through the UK LLP and trust structure.
Now, amid policy uncertainty, they are reviewing holidays, allowing income streams and restocking credit to secure future eligibility.
“If these reforms are carried out in writing, we may need to relax part of the trust or explore reorganization,” said Trustee Mark Bennett.
Outlook: Tax shelter, but how long?
Despite the turmoil, farmland offers unparalleled advantages: scarcity, cultural capital, diversification and long-term tax shelter. But the rules are no longer guaranteed. Savills reported a 30% increase in farmland acquisitions through trust and family investment firms in the second quarter of 2025 as consultants were eager to secure current relief before enacting any legislative changes.
“It used to be an audit of the evergreen shelter,” Pemberton said.
Conclusion: Invest in land – But please be alert
Farmland still offers a unique blend of prestige, conservation and performance in the UK. But the future of tax efficiency in the industry is under scrutiny and the action window may be closing.
For HNWIS and business owners seeking stability, the message is clear: Invest in land – but with a sense of urgency, vision, and a team that understands soil and regulations.
