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KEY POINTS
- Nature of business property relief.
- BPR can apply to certain business assets.
- Reduction of the value of the asset in the transferor’s hand.
- Taxpayers may be able to make late BPR claims.
Business property relief has often been thought of as a relief applicable to transfers of different categories of property.
The danger with this approach is that it wrongly focused attention on identifying the nature of the property transferred and on whether or not it met the definition of ‘relevant business property’ contained in IHTA 1984 s 105.
Instead the correct approach is to identify the transfer of value that has resulted in a reduction in the value of relevant business property in the transferor’s estate regardless of whether an actual transfer of the property takes place: so held the High Court...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
