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High Court Hears Challenge to Labour’s Inheritance Tax Reforms Over Alleged Unlawful Consultation

The case tests whether ministers had to run a full public consultation under the Treasury’s 2011 framework.

Overview

  • A two-day hearing opened at the Royal Courts of Justice before Lady Justice Whipple and Mr Justice Fordham, with judgment expected in the coming months.
  • Farmers Tom and George Martin, the campaign group Farmers and Businesses for Fair Tax Relief, and Alvarez & Marsal argue the Treasury failed to follow the 2011 Tax Consultation Framework.
  • Counsel for the claimants said the framework required at least one public consultation on the APR and BPR changes, while the government only consulted on a limited trusts proposal.
  • House of Commons Speaker Lindsay Hoyle was allowed to intervene on parliamentary privilege concerns as the Finance Bill is before the House of Lords, with his submissions due Wednesday.
  • The reforms tightened APR and BPR announced in October 2024, with a December shift raising the threshold to £2.5m (£5m for couples) from April 2026, which the government says cuts newly liable estates to about 1,100 from roughly 2,000.