BPR changes versus commercial reality: Minority shareholders in focus

The 100% rate of business property relief (BPR) for UK inheritance tax (IHT) purposes will be abolished in April 2026 to be replaced by an allowance of £2.5m. Given that the allowance can be taken advantage of by both individuals as well as trustees (where conditions allow) business owners may be considering restructuring their shareholding into multiple ownerships in order to take full advantage of the new regime. But what are the implications of bringing in additional shareholders? One may say that so long as the founder retains day-to-day control, the business ought to be able to c...