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Q: My client intends to gift his shares in an unlisted trading company to his children before the changes for Business Property Relief (BPR) begin on 06 April 2026. Should the client pass away within 7 years but after 06 April 2026, will the shares still qualify for 100% BPR relief upon his death?

A: The gift of the shares will be classified as a Potentially Exempt Transfer (PET). If the PET is made between 30 October 2024 and 06 April 2026, it falls into what HMRC refers to as the "transitional period." Therefore, if the client makes a PET during this period and passes away after 06 April 2026 but within 7 years from the date of transfer, there is an allowance of £1 million instead of full relief. Any balance over £1 million will be subject to an effective rate of inheritance tax (IHT) of 20%.

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