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BPR replacement

13 June 2007
Issue: 4112 / Categories: Forum & Feedback

IHTA 1984, s 107(2) provides that, 'in a case falling within s 107(1), relief under this Chapter shall not exceed what it would have been had the replacement or any one or more of the replacements not been made'.

IHTA 1984 s 107(2) provides that 'in a case falling within s 107(1) relief under this Chapter shall not exceed what it would have been had the replacement or any one or more of the replacements not been made'.
It would seem that if the original investment in business property had been held for two years the replacement business property held for a lesser period would qualify. Does s 107(2) merely cap the relief for the replacement of business property at the value of the original investment or does it mean that replacement of relevant business property will not qualify for relief unless the original investment had been held for two years?
I should be most grateful if Taxation readers could provide some clarification here.
Query T17 023 – All Change.

 

Reply by Belgravia:

There are three reasons to suppose that IHTA 1984 s...

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