Family farmers and business owners have mounted a judicial review at the High Court, arguing that recent inheritance tax reforms targeting family enterprises were introduced without adequate consultation.
The two-day hearing, which began in London on 17 March 2026, challenges measures announced in the Chancellor’s October 2024 Budget that altered reliefs for agricultural and business property.
Claimants, including the campaign group Farmers and Businesses for Fair Tax Relief, contend the process breached established government consultation commitments, putting multigenerational businesses at risk of higher tax burdens.
The proceedings come amid visible protests from the agricultural sector, who continue to voice concern about the potential impact of the revised policy.
Overview of the Legal Proceedings
The judicial review centres on whether government officials, led by Chancellor Rachel Reeves, failed to conduct proper consultation before unveiling changes to inheritance tax affecting family farms and businesses.
Lawyers for the claimants argue the process did not meet the expectations set out in the Treasury’s own Tax Consultation Framework. The High Court is being asked to rule on whether this shortcoming renders the reforms unlawful or compels further stakeholder engagement.
Protest action accompanied the start of the hearing, with farmers driving tractors through central London and gathering outside the Royal Courts of Justice.
The case highlights ongoing tension between the government’s fiscal policy objectives and the interests of rural and business communities.
Background to the Inheritance Tax Reforms
The contested reforms, announced in October 2024, targeted two forms of relief – agricultural property relief (APR) and business property relief (BPR).
These changes initially lowered the tax-free threshold for inheritance of family-held assets, exposing a greater share of these businesses to the standard 20 per cent inheritance tax rate on estates valued above £1 million.
Widespread criticism prompted a government amendment in December 2025, increasing the threshold to £2.5 million for individuals and £5 million for married couples.
The change was intended to ease the impact, but campaigners note that significant numbers of farm and business owners still face considerable inheritance tax liabilities under the new framework.
Details of the Judicial Review
The legal claim, fronted by Cambridgeshire farmer George Martin and his son Tom Martin, asserts that the Treasury did not follow its March 2011 Tax Consultation Framework, which stipulates that government should consult openly on 'significant tax changes'.
The claimants maintain that the opportunity to make representations was not provided, leaving stakeholders unable to influence the design or implementation of the new tax policy.
Legal representation for the group described the lack of engagement as having 'deprived the claimants of an opportunity to present their case and voice their concerns' and argued that this procedural failing amounted to unlawful conduct by the Chancellor.
Farmer and Business Reaction
Farmers and business leaders have expressed strong opposition to the inheritance tax reforms and the way in which they were developed. Tom Martin, who is jointly leading the legal challenge, stated,
'This legal case matters to everyone affected by the proposed tax changes, and I am proud to speak for the concerns of farmers and business owners whose livelihoods would be impacted.' Business figures, such as Steve Perez, chief executive of Global Brands, have also intervened, noting the urgency and unexpected nature of the policy.
'This came out of the blue. I think they don’t understand the impacts,' Perez commented. The visible protest and legal action underscore longstanding concerns about the effects of inheritance tax changes on the succession planning and financial viability of family-run enterprises.
Consultation Controversy
At the heart of the judicial review is the question of whether the government adhered to its own standards. James Austen, a partner at law firm Collyer Bristow representing the claimants, said,
'The Government’s Tax Consultation Framework… was put in place because proper consultation is vital in getting tax changes right first time.' Austen argued that such consultation prevents 'damaging unintended consequences and embarrassing U-turns,' referencing the threshold adjustment made after public backlash.
Supporters of the legal challenge assert that meaningful engagement could have mitigated some of the controversy associated with the reforms.
Final Summary
The High Court’s review of inheritance tax changes for family farms and businesses has brought to the forefront issues of consultation, economic continuity, and fairness in tax policy.
With claimants contending that the reforms threaten the viability of multi-generational enterprises and that insufficient consultation breached established norms, the eventual judgment could reshape how major fiscal measures are devised in future.
As farmers and business owners await the High Court’s decision, attention is likely to remain on the need for transparent policy processes that balance government objectives with the interests of affected communities.
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