Business Relief (BR) qualifying investments are one of the ways advisers can help reduce a client’s potential future inheritance tax (IHT) liability, alongside gifting, trusts and other estate planning strategies. One reason advisers may consider BR-qualifying investments is that relief may apply after two years of ownership, compared with the seven-year period typically associated with potentially exempt transfers such as lifetime gifts. Investors may also retain access to their capital, subject to the terms and liquidity of the investment, unlike with an outright gift. However, BR qualifying investments are typically higher-risk, unquoted investments, and the value of an investment can go down as well as up.

Not every BR-qualifying investment works in the same way. Differences between services can include the underlying asset class, whether protection is provided during the two-year period before relief applies, and the terms on which an investor can access their money. This article examines what one such service, Ingenious Estate Planning (IEP), offers.

What is Ingenious Estate Planning?

IEP is Ingenious’s range of Business Relief qualifying investment services, available through IEP Apex and IEP Private Real Estate. Both provide investors with a discretionary investment management mandate under which Ingenious Capital Management Limited (ICML, the Manager) selects and manages a portfolio of shares in one or more BR-qualifying companies.

The underlying investment strategy focuses on asset-backed lending within the real estate sector and is intended to provide investors with exposure to a BR-qualifying investment strategy, alongside complimentary access to services such as insurance cover, where applicable, and specialist care advice.

Both strategies follow the same lending model. A key distinction between them is that IEP Apex includes insurance cover during the two-year qualifying period, while IEP Private Real Estate does not.

The core activity of the Service is asset backed lending in the real estate sector.

What does an IEP investment provide?

01 Business Relief on qualifying shares

02 Immediate insurance cover with IEP Apex

once shares are alloted

03 Asset backed real estate lending strategy

04 Access to investors' money

05 Investors’ Relief

Business Relief on qualifying shares

Once shares have been held for two years, they may become eligible for Business Relief. From 6 April 2026, the first £2.5 million of an individual’s qualifying assets can receive 100% relief. This allowance applies per individual, and any unused allowance may generally be transferred to a surviving spouse or civil partner, meaning a married couple or civil partners could potentially obtain 100% relief on up to £5 million of qualifying assets. Qualifying assets above the available allowance may receive relief at 50%. Business Relief depends on the circumstances at the time of a transfer, usually on death, and entitlement is determined by HMRC rather than guaranteed in advance.

Do you have clients with existing BR-qualifying investments?

If an investor switches from another BR-qualifying asset into IEP, replacement relief may apply. Where the sale proceeds of the original investment are reinvested into IEP within three years of disposal, the new investment may qualify without waiting a further two years, provided the combined ownership of the old and new assets totals at least two years within the five years preceding the transfer. The relief available on the replacement investment cannot exceed the relief that would have applied to the original asset. Where relevant business property is inherited from a spouse or civil partner on death, the recipient may generally inherit the deceased’s period of ownership for Business Relief purposes.

Immediate cover with IEP Apex once shares are allotted

IEP Apex includes complimentary cover under a group life insurance policy. Once shares are allotted, if an investor dies during the two-year qualifying period, the policy can pay up to 40% of the initial subscription value, subject to a maximum benefit of £200,000.  There is no additional charge for the cover and no medical examination is required. To be eligible, investors must be aged between 18 and 86, be UK resident, be registered with a UK doctor and complete a Health Declaration. IEP Private Real Estate doesn’t include this cover.

A defined investment strategy

The investment strategy seeks to generate returns through secured lending to real estate projects, rather than relying on capital growth or market timing. The IEP targets a long-term return of 3% to 5% per annum, net of fees, over a five-year rolling period. This is a target, not a promise: the value of an investment can go down as well as up.

Access and withdrawals

Investors can request regular withdrawals, or a partial or full redemption after an initial 12-month holding period, subject to available liquidity. A partial withdrawal reduces IEP Apex’s insurance cover in proportion, and a full redemption ends it.

Investors’ relief

During lifetime

Gains may qualify for Investors’ Relief once shares have been held for at least three years, giving a reduced capital gains tax rate of 18% for qualifying disposals made on or after 6 April 2026. The relief is subject to a lifetime limit of £1 million of qualifying gains.

On death

If an investor dies holding shares, the base cost is generally uplifted to the market value at the date of death, meaning no CGT is payable on gains accrued up to that point. If the investor’s executors later sell the shares, CGT may be payable on any increase in value arising after death. The executors’ base cost will be the market value at the date of death, and any gain realised on a subsequent disposal will generally be subject to CGT at 24%, Investors’ Relief would not normally be available to executors in respect of a post-death disposal. Any gain may be reduced by the annual exempt amount available to executors, which is £3,000 for the 2026/27 tax year, provided the estate remains within the period for which the exemption is available.

 

For full details of the investment strategy, risks, charges, liquidity considerations and eligibility criteria, please refer to the relevant IEP Apex or IEP Private Real Estate Brochure and Investor Agreement.

Additional care service

All IEP investors receive complimentary access to the IEP Care Service, delivered by independent care adviser Grace Consulting. The service provides guidance on care options, a bespoke search for local providers and information on likely care costs for investors and their immediate family.

The IEP Care Service offers:

  • Visit: Personalised visit or phone conversations with a dedicated specialist to assess the specific situation.
  • Guidance: Guidance on appropriate care options for the circumstances with the individual’s best interests at heart.
  • Search: Detailed, bespoke search and assessment of the most appropriate, local providers.
  • Advice: Advice about potential cost of care in the area and how to prepare.

Grace Consulting provides independent care advice, and is not registered with the FCA as it is not authorised to provide financial advice.

My experience of planning for my husband’s care needs changed overnight with the use of the IEP Care Service. The value of being listened to and having someone spend the time to thoroughly consider his options has given me total confidence that he is now receiving the best possible care.

– IEP Care Service client

Common questions

Which IEP option includes insurance cover during the two-year qualifying period?

Only IEP Apex. It can pay a benefit of up to 40% of the initial subscription, up to a maximum of £200,000, provided the investor meets the eligibility criteria: aged 18 to 86, UK resident, registered with a UK doctor, and a completed Health Declaration. IEP Private Real Estate does not include this cover.

Is Business Relief guaranteed after shares have been held for two years?

No. Business Relief is not guaranteed simply because shares have been owned for two years. The underlying company must continue to meet the qualifying conditions for Business Relief, including carrying on a qualifying trade. Eligibility is assessed by HMRC based on the facts and circumstances at the time of a transfer (usually on death). The two-year ownership requirement is a necessary condition for relief but meeting it alone does not guarantee it.

What is the minimum investment for IEP?

£25,000, with no maximum. Subscriptions above £500,000 do not receive additional insurance cover beyond the £200,000 maximum if you invest in IEP Apex.

Can a client access their money before the two-year qualifying period ends?

Generally, yes, after an initial 12-month holding period, subject to available liquidity. A partial withdrawal reduces IEP Apex’s insurance cover in proportion, and a full redemption ends it.

What tax applies if a client sells shares during their lifetime?

Investors’ Relief may reduce the capital gains tax rate to 18% once shares have been held for three years, subject to a £1 million lifetime limit.

TECHNICAL TEAM

Simon Palmer

Simon Palmer

Group Technical Director

Sebastien Couplez

Sebastien Couplez

Technical Director

Jack Ingilby

Jack Ingilby

Technical Manager

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Ingenious Insights: more from the adviser education series

01

What is inheritance tax and who pays it?

A plain-English guide for advisers: how inheritance tax works, the key allowances and why more estates are affected than ever before.
02

What is Business Relief?

How Business Relief works, what qualifies, and what's changing from April 2026, including the new £2.5m allowance and the AIM shares change.
03

Inheritance tax changes 2026

A practical summary of the April 2026 inheritance tax changes and the steps advisers should take to protect their clients' estate plans now.
04

What does an investment in IEP provide?

An adviser's guide to what an IEP investment provides: Business Relief, optional insurance cover, a defined strategy, access to capital and Investors' Relief.
05

How does a Business Relief investment compare to other estate planning options?

Business Relief investments, gifts, trusts, AIM shares and life insurance for inheritance tax compared: the advantages and risks of each estate planning solution.
06

Business Relief and Trusts

Entry, periodic and exit charges explained for discretionary and interest in possession trusts, with worked examples and how Business Relief can help.

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