The Glastonbury festival is a uniquely British institution, calling bands, artists and more than 200,000 fans together for a weekend of live music and performance.
It is also a valuable asset for its founder Michael Eavis, generating around £68 million in revenues and pre-tax profits of around £6million.
The festival is structured with a company, founded in 1992, yet a large proportion of its profits are famously donated to charities including Oxfam, WaterAid and Greenpeace.
Before the headline acts and the crowds descended on Worthy Farm this year, Sir Michael Eavis, now aged 89, transferred most of his financial interest to his daughter, Emily, and to a family trust.
It was a decision no doubt driven in part by the Government 2024 Budget that effectively removed Agricultural Property Relief (APR) and Business Property Relief (BPR).
The transfer of assets and shares to a family member are not liable for inheritance tax (IHT) if the person making the gift survives for seven years, under the potentially exempt transfer rules. If the individual dies after three and before the seven-year cut-off, the amount of IHT will be reduced on a sliding scale.
Placing shares in a trust can reduce exposure to IHT, removing them from an estate on death. However, charges can be incurred at the point of transfer and on every 10-year anniversary.
APR and BPR
APR and BPR have been essential reliefs for farming and family-owned businesses, allowing them to shield business assets critical to the future success of the farm or business from IHT.
The Government’s Budget in October effectively overturned those reliefs. From April 2026, individuals will have a £1million combined allowance for APR and BPR assets that qualify for 100% IHT relief. Over and above that, APR and BPR assets will qualify for just a 50% relief from IHT.
Anti-forestalling measures were also announced in the Budget that means where lifetime gifts were made on or after 30 October 2024 and where the donor dies on or after 6 April 2026 (within 7 years of the gift), those gifts will fall into the estate for IHT purposes.
It is a controversial change that has been criticised for the potential it has to break up family-owned farms and family businesses, such as Worthy Farm and the Glastonbury festival.
There is, however, a short window of opportunity to mitigate against these changes.
Every farming and family-owned business will be different, and it will be important to understand the impact of these changes. We recommend:
- Businesses review how assets are owned within the family.
- Review and understand the value of assets held by the business and family and the potential IHT liabilities.
- Consider making lifetime gifts to ensure the £1 million allowance is used and not lost.
- Review existing trust arrangements.
- Explore how new trusts can be used to mitigate against these changes.
- Consider how future IHT liabilities might be funded, including the use of insurance policies.
Contact our Private Client Solicitors
If you are in need of advice or assistance on any of the legal issues mentioned in this article, please contact any member of our experienced Private Client team on 020 7631 4141 or email privateclient@bishopandsewell.co.uk
The above is accurate as at 30 June 2025. The information above may be subject to change.
The content of this note should not be considered legal advice, and each matter should be considered on a case-by-case basis.
