Key takeaways
Business owners need to be aware of the changes to Inheritance Tax
This has put succession planning firmly on the boardroom agenda.
The death of a shareholder could cause far-reaching issues for the business
This is now a significant business risk, for business continuity and governance.
Planning opportunities are still available for business owners
Planning needs to be implemented and reviewed in light of the new rules.
When the chairman of family-owned Samsung, Lee Kun-hee, died in 2020 his estate was left with an Inheritance Tax liability in South Korea of £6 billion.
At the time, the technology giant was faced with questions over whether Samsung could remain within family ownership given the size of the tax bill in question.
Selling shares to pay the tax would have resulted in a loss of family control over the business, which raised huge concerns around the governance of the company going forward.
A shift in the risk landscape
This is now the reality for business owners in the UK following the recent changes in April 2026 to Business Property Relief for Inheritance Tax. In practice, these changes bring succession planning firmly into the centre of business risk management.
It’s no longer just about tax efficiency, but about ensuring that ownership transitions do not disrupt decision-making, strategy or day-to-day operations. Reviewing governance frameworks, funding mechanisms and shareholder agreements will be key to maintaining continuity.
The exposure to additional tax on death, and how this is funded, is now a real concern for shareholders. It also raises issues in the boardroom, as the death of a shareholder may create tangible risks around governance, operational efficiency and the ongoing stability of the business.
While the landscape has shifted, it also presents an opportunity for business owners to reassess existing structures and ensure they remain fit for purpose. Early, informed planning can support orderly transitions, manage potential liabilities and provide greater clarity for all stakeholders.
Planning for continuity
The good news is there are still opportunities to plan, be it to mitigate exposure to Inheritance Tax, put in place contingencies to meet the additional tax bill, or ensure good governance is established and maintained for the business following the death of a shareholder.
Our Private Client and Corporate teams work closely with business owners to develop tailored, practical strategies that support both long-term business resilience and family objectives.
