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The inheritance tax (IHT) landscape is undergoing its most significant reform in decades. As we approach the introduction of Business Relief (BR) allowances and tiered relief in April 2026, advisers face a new set of challenges. With frozen IHT thresholds creating fiscal drag¹, bringing more estates into scope for IHT and the inclusion of pension assets within the IHT net, the rules of engagement for estate planning are changing fast.

The changes to BR in 2026 mean that qualifying unlisted shares will continue to attract 100% IHT relief up to £1 million and 50% beyond that – resulting in an effective 20% IHT rate above the threshold². Meanwhile, AIM listed shares will receive a flat 50% relief, also equating to a 20% effective rate from the first invested pound.

Against this backdrop of changing legislation, advisers are having to revisit existing plans with clients and, in some instances, start over again. The role of BR in those plans will also need to change. Many will be looking to incorporate it into clients plans for the first time, while others will have to revisit existing arrangements to see if they are still fit for purpose.

However the conversation goes, it’s important to pick the right partner to work with. Here’s why advisers trust Downing as their estate planning partner:

1. Support evolving client goals

The IHT consultation paper, which closed on 23 April this year, clarified that the £1million BR allowance will recharge, in line with normal gifting rules, every seven years. This indicates an opportunity for longer term planning with BR, starting with younger clients, as this will bring new considerations for advisers. Should you opt for a capital-preservation strategy with lower targeted returns - but a more favourable tax regime - or, with a longer expected time horizon, allowing clients exposure to greater volatility in pursuit of higher returns in listed markets?

Downing offers a flexible suite of estate planning strategies designed to meet a range of client preferences. These include unlisted, listed, and corporate-focused solutions - allowing advisers to align client investments with a variety of objectives.

Downing’s long-standing expertise in this market has seen industry recognition including the award of ‘Best Tax and Estate Planning Solutions Provider’ at the 2024 Investment Life & Pensions Moneyfacts Awards. Downing is shortlisted again for 2025.

2. Breadth of experience and governance oversight

Established in 1986, Downing is one of the oldest specialist investment managers in the BR market. With a team of over 260 staff across five offices in five different countries spanning investment, legal, compliance, engineering, responsible investing and operational disciplines, Downing can demonstrate a broad expertise and experience operating in our chosen markets. Success in these markets comes from sound investments but our commitment to excellence goes beyond how we invest funds and extends to our culture of strong governance and active management for long-term value. Downing was recently assessed by AKG and received an 'effective' operational rating – reflecting the robustness of our governance framework, corporate structure, and compliance processes.

3. Track record through multiple market cycles

Where this structure and experience really plays out though is in the investments themselves. Advisers want to see long-term performance that supports client outcomes through changing market conditions.  

Downing has been managing estate planning solutions for nearly two decades – supporting advisers and their clients across multiple market cycles. Our long-term track record reflects that experience: 

• ‍DEPS has outperformed its target, delivering a 4.7% annualised return over five years and 51.6% cumulative return since inception in 2012³.
• ‍DAEPS has consistently outperformed the market with a 182.7% cumulative return since inception in 2012, compared to AIM's⁴ 11.8% over the same period³ - reflecting consistent active management through market cycles.

‍Performance figures are net of all Downing fees.
Past performance is not a reliable indicator of future perfomrance.

4. Integrated protection and peace of mind

Advisers are increasingly seeking ways to reassure clients about risk – particularly around short-term market fluctuations or the potential impact of death occurring during the minimum two year holding period. One growing area of interest is estate planning solutions with built-in protective features.

Downing’s Wealth Guard provides unique cover for falls of up to 20% of an investor’s net initial investment, upon exiting the investment following death within the first two years. This protection is included at no extra cost and is backed by an A-rated insurer.⁵

5. A responsive partner in a changing environment

Estate planning is no longer a one-off decision – it’s a continuous process that requires adaptable support. Advisers increasingly want providers who offer more than just a product, but a long-term partnership.

Downing's focus is on being a responsive, knowledgeable partner throughout the client journey. Our adviser-facing team includes 29 regional sales professionals who provide boots-on-the-ground support for face-to-face meetings, local events and tailored client planning. Our dedicated Adviser Hub provides a suite of resources including CPD-qualifying content, practical toolkits and case studies to help advisers meet their objectives, improve their understanding of technical tax scenarios, bolster their relationship with clients, and meet their regulatory responsibilities.

Explore our estate planning strategies at Inheritance Tax Solutions - Specialist IHT Products | Downing or contact our team for adviser-focused support on 020 7416 7780.

The article was written by:

Nick Priest

Partner and Head of Strategic Partnerships

References

¹Fiscal drag occurs when inflation or income growth pushes taxpayers into higher tax brackets, resulting in increased tax revenue and reduced consumer spending, which can slow economic growth.
²Changes to agricultural and business property reliefs for inheritance tax - House of Commons Library
³As at 31 May 2025
⁴FTSE AIM All-Share Total Return
⁵Up to the age of 90 years; covers up to £750,000; T&Cs apply, see policy for full details

Important notice

Opinions expressed represent the views of the author at the time of publication, are subject to change, and should not be interpreted as investment advice.

Past performance is not a reliable indicator of future performance.

This article has been approved and issued as a financial promotion. This content is for information only and does not form part of a direct offer or invitation to purchase, subscribe for or dispose of securities and no reliance should be placed on it. Whilst care has been taken in compiling this content, no representation or warranty, express or implied, is made by Downing LLP as to its accuracy or completeness, including for external sources (which may have been used) which have not been verified. Downing is a trading name of Downing LLP. Downing LLP is authorised and regulated by the Financial Conduct Authority (Firm Reference No. 545025). Registered in England and Wales (No. OC341575). Registered Office: 10 Lower Thames Street London EC3R 6AF.