I found the responses to the query Partnership land a little alarming. They may require some further thought which I will have to put to one side for the present. However it may be useful if I voice my concerns.
I think perhaps that too much emphasis is being placed on the business owning the asset – which may be correct for some aspects but perhaps not in the context of obtaining 100% inheritance tax business property relief.
I do not think IHTA 1984 s 110 requires any form of ‘ownership’ but rather that the asset should be one by reference to which the net value of the entire business would be ascertained.
Any particular partnership asset may be part of the formula to determine profit and...
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