A wildlife park in Watford that boasts zebras, American bison and capybaras is facing closure, with its owners blaming planned changes to Inheritance tax (IHT) and more specifically those relating to agricultural property relief (APR) and business property relief (BPR).
The Cassiobury Farm has been built by husband-and-wife team Steve and Katie Cardell over the past two decades and is now home to more than 70 exotic species, together with a fishery and farm shop.
In press reports, the Cardells, who have put the business up for sale with a price tag of £2.75 million, say that changes to APR and BPR would leave them with a potential seven-figure tax liability if they wished to pass it on to their children.
Their decision to sell before the changes to APR and BPR take effect in April 2026 should serve as a reminder to other family-owned businesses facing similar IHT challenges.
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 inheritance tax.
From 6 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.
It is a controversial change that has been criticised for the potential it has to break up family-owned farms and family businesses. There is, however, a short window of opportunity to mitigate against these changes.
The government’s 2024 Budget announcement said the new rules would apply to lifetime trusts from 6 April 2026, creating an ever-shortening window of opportunity for farming and family-owned businesses to ‘bank’ IHT reliefs (as long as the donor lives for seven years after the transfer).
Every farming and family-owned business will be different, and it will be important to understand the impact of these changes. We recommend:
- A review of any previous estate planning and particularly for married couples and civil partners to ensure the £1m allowance on first death is utilised.
- A review of the business generally to understand how assets are owned within the family, its value, potential exposure to IHT and consideration of other reliefs which may apply.
- Consider making lifetime gifts to ensure the £1 million allowance is used and not lost. The gifts out of surplus income relief can also be valuable and often underutilised.
- A review of any existing trust arrangement and exploring how new trusts can be used to mitigate against these changes There is only a small window of opportunity between now and 6 April 2026 where the transitional rules apply.
- Consider how future IHT liabilities might be funded, including the use of insurance policies.
These changes are complex, far-reaching and the appropriate action depends much on the specific circumstances of your business. It is therefore essential that farming and family-owned businesses take advice as early as possible to understand its impact before taking action.
Contact our Private Client Solicitors
For further advice or guidance on inheritance planning, to agricultural property relief (APR) and business property relief (BPR), 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 13 October 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.
