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Holding shares in a trading company by way of a partnership is not a bar to business property relief
KEY POINTS
- Unquoted shares in trading companies are relevant business property.
- Limited liability partnerships are treated as other partnerships.
- HMRC consider that relief is not available where unquoted shares are not held directly.
- The impact of the case of RCC v Nelson Dance.
- Over-reliance on the concepts of “transparent” and “obscure” does not help.
It is often the case that shares in a trading company are held through an investment partnership as indicated by Partnership Holdings (below; click image to enlarge).
Typically this is a limited liability partnership (LLP) but the type of partnership does not usually matter because IHTA 1984 s 267A (below; click image to enlarge) directs that an LLP is to be treated in the...
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