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Farmers and Agricultural Business Inheritance Tax (IHT Reliefs)

By Stephen Meredith

Farmers are very well treated by the IHT rules and farming is the only type of business where the proprietor can claim an exemption from IHT on their home.  However, farmers are notoriously poor at keeping records and there are a number of pitfalls which need to be avoided if the farm is to be passed smoothly down to the next generation without adverse IHT or CGT consequences.

Turning to the farmhouse first, there are 2 conditions that must be satisfied if the farmhouse is to be eligible for 100% Agricultural Property Relief (APR):

1.      It must be ‘occupied for agricultural purposes’ ie one or more individuals who are involved in the faming business must live there eg a sole trader or 1 or more of the partners in a farming partnership

2.      It must be ‘of a character appropriate’ to the land being farmed ie in broad terms, the bigger the farmhouse, the more land that must be farmed with it

The golden rule to avoid falling foul of the first test is that a farmer should never retire no matter what age he is. The simple reason for this is that if, for example, an elderly famer is still living in the farmhouse, if he retires, the farmhouse will no longer be ‘occupied for agricultural purposes’ and will therefore be fully exposed to IHT at 40%.  Please note that farmers will not generally qualify for the new Residence Nil Rate Band (RNRB) – see separate article – since the high value of agricultural land usually means that the value of their assets exceeds the £2 million limit. In any event the RNRB will be capped at £350,000 from 6 April 2020 and farmhouses are often worth considerably more than that.

If we take, for example, the not uncommon case of a father and son where, over time as Dasd gets more frail,  the son has taken over responsibility for the bulk of the farming operation, there is no reason why the 2 of them should not farm in partnership with the son taking a larger profit share. The key thing is that the father should remain as a partner, perhaps with a 10% or 15% profit share, thereby ensuring that the farmhouse remains eligible for 100% APR.  Of course, if the son was also living in the farmhouse with his father then the farmhouse would then be being ‘occupied for agricultural purposes’, regardless of the status of the father. However, where, as is common, the father retains an interest in some or all of the land being farmed, there may be other good reasons (see further below) why he should remain as a partner until he dies.

Turning to the bare land itself, generally whether the land is being farmed by the owner or another person, the land will qualify for 100% APR.  If the land is being farmed in hand, then a minimum 2 year ownership period is required in order to claim APR although where the land has been inherited from a spouse, the spouse’s period of ownership can be included. Where the land is being farmed by a third party, 100% APR can generally be claimed, subject to a minimum ownership period of 7 years. Accordingly where the land is tenanted, provided it has been owned for 7 years, 100% APR can be claimed except where it is subject to an old-style Agricultural Holdings Act tenancy entered into before 1 September 1995 where there is no right to vacant possession within 2 years, in which case only 50% APR is available. Please note, however, that in the latter case, such a tenancy can be converted into a post 1 September 1995 tenancy qualifying for 100% APR, although great care must be taken to avoid triggering adverse CGT charges on the surrender of the old tenancy.

It is also important to note that, where land has been let out and the landlord continues to occupy the farmhouse, the farmhouse will no longer qualify for 100% APR because it is no longer being ‘occupied for agricultural purposes’ vis it is the tenant, rather than the landlord, who is carrying on the farming business. For that reason, often elderly farmers enter into arrangements such as ‘share farming’ and ‘contract farming’ so that they can claim that they are still farming thereby preserving their entitlement to IHT and CGT reliefs.  However, one can expect HMRC to scrutinise such arrangements carefully to ensure that the landowner retains responsibility for and is actually  carrying out acts of husbandry in relation to the land. If a farmer is proposing to enter into such an arrangement it is important that the terms of the agreement between the landlord and the ‘share’ or ‘contract’ farmer are adhered to and the Accounts reflect the obligations of the parties eg in relation to buying seed or fertiliser.

It is also important that detailed records are maintained of the landowner’s involvement in decisions affecting the farming operation and that this is not simply left to the ‘share’ or ‘contract’ farmer. This might take the form of a farm ‘diary’ and can be produced to HMRC if and when required eg after the death of the landowner.

Whether a landowner is farming or not is also important in relation to another type of IHT relief – Business Property Relief (BPR). This is because APR is only available on the agricultural value of land or buildings. If, for example, a farmer owns land or barns with potential development value, then APR will only apply to the agricultural value of such property, not the ‘hope’ value which could be very considerable if, for example, the land is likely to go for housing or barns are ripe for conversion into residential accommodation.  For example, while the agricultural value will probably be in the region of £15,000 per acre, the hope value could be as much as £1 million per acre or even more. If the landowner is farming, then 100% BBR can be claimed on the hope value, whatever that value might be but, if, for example, the land is let out, then BPR will not be available. In the latter circumstances, if the landowner dies owning the land or barns with development potential, then (subject to spouse exemption which, in any case, is only likely to defer the problem to second death) IHT will be payable on the hope value at 40% which could, in an extreme case, force the farm to be sold. 

Conversely, if the landowner is farming then 100% BPR can be claimed on the development value if the farmer dies and this enhanced value will be used as the ‘base cost’ for CGT purposes on any future sale of the land for development thereby minimising any CGT charge on the disposal. It should be noted that even if the landowner has no intention of developing the land or selling it for development, this will not stop HMRC from valuing any ‘hope value’ or assessing it to IHT on his death.

Accordingly, it is very important that all farmers know exactly who owns any farmhouses, land and farm buildings and understands whether, and to what extent, any real property will qualify for APR or BPR.  Steve Meredith who recently joined us has specialised in agricultural work and advising farmers about succession planning and Wills for some 20 years and is very experienced in balancing family needs against tax considerations so that farmers get the best of both worlds. 

For a free consultation please contact Steve at SMeredith@horsey  or on 01685 580858.

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What is Conveyancing?

Andrew Wilson (Trainee Legal Executive in Residential Conveyancing), explains all!


Conveyancing is the legal and administrative process carried out when a house or flat is purchased or sold.

Upon instructing a solicitor to act on your behalf, there will be various anti-money laundering and identity checks to be carried out before any work can be carried out. Once these compliance checks have been carried out, the conveyancing process begins.


The solicitors acting for the purchaser of the property will carry out many searches and investigations on the property and legal documents to ensure that the buyer obtains a good and marketable title upon their purchase. The aim here is to ensure that the purchaser does not have difficulties selling the property in the future.

This process will often also include raising ‘enquiries’ with the seller’s solicitors which will involve resolving legal issues or seeking clarification on unclear arrangements.

This is often the longest stage in any conveyancing transaction as it involves a lot of ‘back and forth’ between the solicitors and a lot of information is required from third parties. For example, local authorities are relied upon to provide information regarding planning and building regulations documents, and management information companies are required to provide many details in leasehold transactions.

Prior to exchange of contracts, there is no agreement in place and either party may withdraw from the transaction without any repercussions.

Exchanging Contracts

Exchanging contracts is the arrangement of the buyer and seller of a property entering into a binding legal agreement.

The buyer and seller will often sign a separate, identical contract that they will leave in the hands of their solicitors, undated, in readiness for exchange of contracts in order for their presence not to be required in the solicitors’ offices on the day, which in most cases would be most inconvenient.

All investigations must have been made prior to exchange of contracts and any legal issues will need to be resolved.

The completion date, or ‘moving date’ is fixed at this stage by agreement of all parties in the transaction (or chain of transactions where a buyer of a property is reliant on the sale of their own). Completion is usually at least five working days after exchange of contracts due to mortgage lender requirements, however, in reality completion can be weeks or even months following exchange of contracts if agreed by the parties.

There are significant financial penalties if either party withdraws from the transaction after exchange of contracts has taken place.


Completion is the date that the purchase monies are paid from the buyer’s solicitors to the seller’s solicitors and the property is transferred from the buyer to the seller. It is also on this date that most buyers will collect the keys to the property and begin the moving process into their new home.

Following completion, the solicitors acting on behalf of the buyer will arrange for their purchase to be registered at the Land Registry and it is at this point that the legal title is formally transferred.

 To seek legal assistance or obtain further information about the above please contact Andrew Wilson of our Residential Conveyancing Department on 01635 580858

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Which survey do I need? - Purchasing a Property

by Andrew Wilson - Trainee Legal Executive, Residential Conveyancing Department


Once you have found your next home, whether it be a house or a flat, you should always consider carrying out a survey before you sign the contract and commit to your purchase.

No purchaser would want to move in to their property and find out too late that the roof is in need of repair, or perhaps that the windows are reaching the end of their life span, or the walls are showing signs of damp. A survey can help avoid the hassle and expense of costly repairs and if not, at least provide you with peace of mind.

You may think that this applies only to freehold houses, but it is just as important to carry out a survey on flats and other leasehold properties. Defects with the building will need to be addressed and paid for by the residents by way of a service charge so your annual or monthly costs may increase more and more beyond the already steadily increasing service charges in blocks of flats all over the country.

If you are purchasing with a mortgage the lender will often carry out a valuation report, so why should you have to worry about instructing a surveyor yourself? In reality, a valuation report is not a survey at all so try not to confuse the two. In most cases the valuer will not even visit the property.

So which survey should you consider carrying out? There are a number of options to choose from.

RICS Condition Report

This type of survey is on the lower end of the scale cost-wise and will highlight urgent defects as well as potential legal issues which, as your solicitors, we would be able to address with the seller’s solicitors.

Each element of the property is given a risk rating from 1 to 3:-

1 – No repairs are currently needed.

2 – Less serious or urgent defects are in need of repair or replacement.

3 – This rating is for defects that are serious and need to be investigated, repaired or replaced urgently.

This survey is aimed at newer homes and relatively conventional properties.

RICS Homebuyer Report

This survey report provides all of the features of a Condition Report as well as additional advice on repairs, defects that may affect the property and ongoing maintenance advice.

This report offers a market valuation as an optional extra which also includes a rebuilding cost for the purposes of insurance.

This survey is suitable for conventional properties which are in a reasonable condition.

RICS Building Survey

This is the most comprehensive report that provides an extremely detailed analysis of the property’s condition. Advice will be given on repairs, defects and maintenance options.

This Survey is essential if you are planning major works or if you are purchasing an older or larger property.

 To seek legal assistance or obtain further information about the above, please contact Andrew Wilson in our Residential Conveyancing Department on 01635 580858

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Are you facing the challenge of divorce and dealing with autistic children or an autistic partner?

by Alison Whistler - Family Department solicitor


 It’s World Autism Awareness Week from 1st – 7th April. The saying goes “If you’ve met one person with autism, you’ve met one person with autism”. I’ve always found that really helpful to remember when advising clients who have children with Autism or Aspergers because their child’s needs will be specific to that child. It’s not helpful to assume they will be like the Dustin Hoffman character in the movie “Rain man” or The Governess from “The Chase”, as they will have their own behaviours and personalities which need to be carefully factored into discussions surrounding the divorce process, so as not to cause unnecessary upset to the child.

I have, over the past 25 years of my family law career, encountered autism in a number of the cases that I have dealt with and, the experience of each case has helped me to help other clients who have this additional challenge to overcome as part of the divorce and separation process.

In some situations, having an autistic child or children may have put an extra strain on the marriage which has led to the relationship breaking down. In other cases, there may be very clear signs that the other parent has autistic behaviours (not always officially diagnosed), which makes co-parenting or meeting the emotional needs of a partner in a relationship a very real challenge.

Whether autism is a factor or not, in a divorce case it doesn’t really matter to me as long as I’m aware of it and can incorporate it into each part of the process. There are lots of issues that are challenging in my job as a divorce lawyer; autism is just one of them. The legal process is generally always the same; it’s just the people, their personalities and behaviours that make every case I deal with different. By adapting the advice I give to clients to their specific situation, a much better outcome for everyone can be achieved. 

 To seek legal assistance or obtain further information about the above please contact Alison Whistler of our Family Department on 01635 580858 

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Social Media

by Ben Castle - Family Department solicitor


Recently, we have experienced a number of cases where the information provided to us by our clients has not matched the image they provide to the public; whilst this would seem largely irrelevant to matrimonial proceedings, what information we allow the wider world to see about us can be contradictory to points to be raised in considering the division of matrimonial assets, and divorce as a whole.

 Take the instance of divorce, for example.  A common issue for practitioners is trying to prove that a spouse has received the divorce papers in the first place.  Whilst this can be remedied in a rather straightforward manner when the parties are both living in England and wales, the problem can be more difficult to resolve when one party is another part of the world; organising the service of legal papers in foreign jurisdictions can be extremely time consuming and expensive.  When the author experienced a case where a spouse living in Indonesia denied receiving the petition, he was rather pleased to discover that the same spouse felt it appropriate to document the papers on her public Facebook account and noted the date received.  Printouts of her profile page and a short statement to the court were all that was necessary to prove receipt and the divorce continued.

 That is not where the usefulness of social media ends – where a spouse argues that following separation, they do not intend to cohabit with a new partner, practitioners are potentially provided with a conundrum of how to refute the assertion.  Granted the existence of a new relationship is not a definitive proof of future living arrangements, but in the absence of a new relationship, an argument that one party intends to live with a new partner tends to raise eyebrows!  However, setting out your relationship status on social media will immediately attract questions of your new relationship. 

 Individuals also need to consider other aspects of their life; elements of social media can be used to convey details of our professional qualifications and skills, job roles and corporate associations.  These details are not missed by practitioners who will question an individual’s links in an attempt to establish and determine whether further, undisclosed, income streams exist, but also professional links that indicate that further assets may be available for consideration as part of a settlement.

 So what can an individual do to protect themselves from suspicion?  The first step is to be open and honest with your solicitor; setting out a person’s position must be consistent when entering into negotiations and inconsistencies may prejudice arguments you may wish to raise.  Secondly, do examine what information you are providing to the world; is seems an obvious point, but if you exaggerate online, people may believe your statements ; remember, “you said it not me”.

  To seek legal assistance or obtain further information about the above please contact Ben Castle of our Family Department on 01635 580858

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What happens when a Trustee loses capacity?

The procedure for dealing with the removal and replacement of a Trustee who has lost or, is losing, mental capacity by Stephen Meredith - Private Client Department.

This is not straightforward and considerable care needs to be taken to get it right. The following will need to be considered:

• Whether the Trust Deed or Will contains an express power of removal
• Removal pursuant to S36 (1) Trustee Act 1925 (‘TA 1925’) either with or without Court approval depending on whether the incapacitated trustee also has a beneficial interest in the property (S36(9) TA 1925)
• Appointment of Additional Trustee pursuant to S36(6A-6D) as inserted by S8 of the Trustee Delegation Act 1999 (‘TDA 1999’)
• Removal by the Court pursuant to S41 TA 1925

Removal by Express Power

Consideration of the terms of the Trust Deed or Will is always the starting place. However, while the appointment of new trustees is nearly always included, it is increasingly rare for modern trusts to contain an express power to remove a trustee. For example, the Kessler standard precedents do not contain such a power.

Removal under S36(1) TA 1925 with or without Court Approval

This section contains a power to remove a trustee who is incapable of acting and to replace them with a new trustee but S36(9) TA 1925 contains an important restriction on this power. S36(9) TA 1925 requires the leave of the Office of the Public Guardian (OPG) to be sought if the trustee who lacks capacity ‘…is also entitled in possession to some beneficial interest in the trust property.’ A ‘beneficial interest’ can include an ‘interest-in-possession’ or ‘life interest’ but not an interest under a discretionary trust.

Accordingly in the classic situation of a married couple jointly owning their home ‘as trustees’ if one of them loses capacity, the other of them cannot invoke s36(1) to remove the incapacitated spouse without leave of the OPG as that spouse owns a half share of the property outright.  However, all is not lost as S36(6A-D) TA 1925 may assist if the property is to be sold (see further below).

Appointment of Additional Trustee for Purposes of Overreaching and Giving a Valid Receipt for the Payment of Capital Monies

The ‘two trustee rules’ require that capital monies arising from the sale of land must be paid to at least 2 trustees (Law of Property Act 1925 S27(2).  S7 TDA 1999 specifically provides that this requirement is NOT satisfied where monies are paid to a ‘relevant attorney’. A ‘relevant attorney’ includes an attorney who is acting ‘both as a trustee and as attorney for one or more other trustees…’ Therefore, returning to the classic case of a married couple who own their home jointly, if one of them loses capacity, the other cannot sell the house acting as both ‘trustee and attorney’ as there is only one person to give a receipt for capital monies. We have already seen that, in these circumstances, S36(1) TA 1925 will not assist to remove the incapacitated spouse without the prior approval of the OPG which will entail time and expense.

However S8 TDA 1999 (as now enshrined in S36(6A-D) TA 1925 comes to the assistance by enabling an attorney under an enduring power (EPA) created after 1 March 2000 to appoint an additional trustee in order to satisfy the 2 trustee rule. For example, in the classic scenario described above, the spouse who has capacity can appoint an additional trustee eg a child or professional to satisfy the 2 trustee rule. It is important to note that in this scenario the incapacitated spouse has not been removed as a trustee (which would require Court approval) but will continue as a trustee, albeit that the spouse holding the EPA will need to sign on their behalf (S1(1)TDA 1925).

Removal by the Court

For various reasons, it may not always be possible to make use of either an express power or the S36 power to remove a trustee who has lost capacity or appears unwilling or unable to act in the administration of the trust. In these circumstances S41(1) expressly permits the court, ‘whenever it is expedient to appoint a new trustee or new trustees.….in substitution for a trustee who….lacks capacity to exercise his functions as trustee….’

The need to invoke this Section may arise where there is a dispute between the trustees as to whether or not a trustee has lost capacity and should be removed or who he should be replaced by. If there is doubt about capacity then an application pursuant to S41 TA 1925 is safer than using the S36 power,  since if the requirements of S36(1) are not met, then the replacement of the’ incapacitated’ trustee would be invalid as would any subsequent decisions of the trustees which could lead to claims being made against the trust.


In short the rules relating to the removal of incapacitated trustees are not straightforward and great care should be taken in applying the correct legislation which in turn will depend upon the particular circumstances of each trust. 

To seek legal assistance or obtain further information about the above please contact Steve Meredith of our Private Client team at or on 01635 580858

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New Tax & Trusts specialist, Steve Meredith

Steve Meredith, to boost Horsey Lightly Solicitors Private Client Department.

Jeremy Fitzgibbon, Managing Partner says “We are delighted to welcome Steve to the firm. He brings huge experience and expertise to the already strong team of Christopher Popham, Vicky Brackstone and Carl Wheeler.  Steve is recognised as one of the leading practitioners in the country for Tax and Trusts work and while he was Head of Private Client at a previous firm, the Department was ranked in the top 25 in the UK.  Steve has practised in the area of Wills. Trusts and Estate Planning for over 20 years and is both a member of the highly regarded Society of Trusts and Estate Practitioners (STEP) and one of the few Solicitors to hold the prestigious Chartered Tax Adviser (CTA) qualification.”

Steve acts for a wide range of clients including business owners, farmers, property developers and private individuals with a particular emphasis on helping people to pass on accumulated wealth to the next generation whilst avoiding or minimising Inheritance Tax (IHT) and Capital Gains Tax (CGT) liabilities.  Steve says “I do this by making full and effective use of Agricultural and Business Tax Reliefs and ensuring that tax efficient Wills are in place.  In particular it is vital that, where clients have children, their Wills are drafted to take advantage of the new Residence Nil Rate Band (RNRB) which was introduced in 2017  and will by April 2020 achieve a potential IHT saving of up to £140,000 for a married couple or civil partners.  This represents a very significant IHT saving but the rules are not straightforward and it is quite easy for the RNRB to be lost by careless Will drafting or placing the home in a trust, only a limited number of which qualify for the RNRB.  Particular care needs to be taken when dealing with a widow or widower who has remarried. In this case it may be possible to claim multiple RNRBs and a potential IHT saving of over £200,000 but the Wills require very careful redrafting to achieve this.

Well drafted Wills can also be used to minimise exposure to care home costs which for many people are a bigger worry than IHT because these can decimate a person’s assets.  Whereas IHT will eat up 40% of the value of your assets above a certain limit (£650,000 for a couple without children and potentially £1,000,000 for a couple with children), care or nursing home fees can rapidly deplete your assets down to £14,250 meaning that there is almost nothing to leave down to your children when you die. Having well drafted Wills in place and changing the ownership of you property to a ‘tenants in common’ basis can protect your estate against the liability to pay care fees.

Steve’s approach to mitigating IHT and care costs for married couples/civil partners is to start with the Wills to ensure that they are fully efficient.  Once the Wills are right then that means that up to £1,000,000 of assets will be free of IHT.  However, for clients who have assets above that value and wish to mitigate their exposure to IHT, then further lifetime planning is required.  This can include gifting assets or setting up trusts for children  and/or grandchildren to assist with school fees or University tuition fees.  Steve says “ many people are nervous of trusts because they have heard horror stories about how complex and expensive they are.  However, modern trusts are very flexible and can be a very useful tool for clients looking to avoid IHT and CGT. Their main benefit is control ie if you simply make an outright cash gift to a child or grandchild then you have no control over how they spend that money, whereas if you put that money into a trust instead, you can control both how and when that money is spent.  Many people are rightly wary of putting too much money into the hands of their offspring at a young age so a trust is an ideal alternative and can run for many years if required, including after the death of the person who creates it.  A married couple can put up to £650,000 (£325,000 each) into trust without adverse tax consequences and, if each of them survives for 7 years, then that will achieve not only a 40% IHT saving of over £250,000 on the monies transferred into the trust but also any growth in value of the monies/investments held within the trust will also be outside the IHT net”.

Steve is always happy to see clients on a ‘no obligation’ basis ie the first meeting is free. Steve says “This makes the client feel more relaxed because there is no doubt that most clients are concerned about legal costs. During the meeting I will explore various options as to how to reduce exposure to IHT liabilities or care costs and, at the end of the meeting once I know what the client wants to do, I will be in a position to give them an accurate indication of the likely costs involved.  They can then go away and think about it and decide whether or not and how they wish to proceed.  I estimate that in 90% of cases I am able to produce either an IHT saving or create some level of protection against care fees.”

If you would like to know more or wish to arrange a free consultation with Steve either at our offices in Newbury or at your home please contact him at or on 01635 517118.

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Life Interest Trust

You want your children from your first marriage to inherit your house but you want to make sure that your new spouse has somewhere to live after you die. What can you do?

It can be difficult to decide who is to benefit from your estate after you have died. This may particularly be the case if the relationship between your family members is not as good as you would like it to be, which unfortunately is not uncommon where step-children are involved

If you want to make sure that your new spouse will still have a roof over their head after you die, one solution might be to give your property to Trustees (these can either be family members or professionals or a combination of the two) on terms that they will allow your spouse to live in the house for the remainder of their life. On the death of your spouse, your children and/or grandchildren (or, indeed, any other nominated person) can then inherit the house This is known as a ‘Life Interest ‘ or ‘Interest-in-Possession (IIP)’ Trust.
The key point to note here is that, while your spouse has the right to live in the house rent free during their life time (and this usually includes the flexibility to downsize if they so wish), they cannot alter the ultimate destination of the property after their death ie the terms of the trust will ensure that it eventually passes down to your children/grandchildren.  
The transfer of the property into the trust will be treated for Inheritance Tax (IHT) as a gift from you to your spouse and will therefore qualify for spouse exemption. However, it is important to remember that the value of the property at the date of your spouse’s death will be included in the value of their estate for IHT purposes but importantly, if your children/grandchildren are the ultimate inheritors of the house,  the Residence Nil Rate Band (‘RNRB’) can potentially be claimed by your Trustees to reduce the IHT bill – (see detailed RNRB article on website).
If you would like to talk to us about Life Interest or IIP Ttrusts please do not hesitate to contact Steve Meredith  of our Private Client team on 01635 580858 or at

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Will the Imminent Increase in Probate fees affect you or your family?

You may well have heard about the recent intention to increase the court fees payable when applying for a Grant of Representation.

For many years the fee has been set at a flat rate of £215 for a personal application (£155 for an application by a Solicitor) but in future (from 1 April 2019) the amount of the court fee will depend on the net value of an estate for probate purposes.

This will result in estates valued at between £500,000 - £1m having to pay £2,500 (an increase of £2,285), estates valued at between £1m - £1.6m having to pay £4,000 (an increase of £3,785), estates valued at between £1.6m – £2m having to pay £5,000 (an increase of £4,785) and estates valued above £2m having to pay £6,000 (an increase of £5,785).
The proposed fee increase has been dubbed by a House of Lords committee as a ‘stealth tax’ and there has been much anger at the proposed increase. However, it appears that, with the Government distracted by Brexit, the increase will go ahead as planned.
If you would like to discuss whether and how how this is likely to affect you or your family please do not hesitate to contact Carl Wheeler of our Private Client team on 01635 580858 or at

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Newbury and District Agricultural Society

Grab 10% off your Wills in February!

If you are a Berkshire Show follower on Facebook, have a look at the offer that our Private Client Department has this month! 

Give us a call if we can help. 01635 580858. 

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