Property parent problems

The Readers’ Forum query Property parent and its replies looked at the position where a parent company held the shares in its trading subsidiary and the property from which the subsidiary traded.

The question was whether the shares would qualify for inheritance tax business property relief. The footnote to the query noted that there was uncertainty here and that we would be seeking further guidance from HMRC.

HMRC’s comment on the Readers’ Forum query and replies was as follows:

‘Every case depends on its own facts. However in the case of a parent company holding shares in subsidiaries that do not themselves fall within IHTA 1984 s 105(3) and also holding the property from which the subsidiaries carry on their business it would usually be the case that the main business of the parent company is...