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Horses for courses
KEY POINTS
- The Upper Tribunal upholds the decision of the First-tier Tribunal in Vigne.
- The Pawson case held that owning and holding of land for income is likely to be an investment activity.
- The Upper Tribunal might have reached a different decision but the lower tribunal had not erred.
- A ‘fact and degree’ approach is required to decide whether there was a business of holding investments.
- In Stedman’s Executors the Court of Appeal could not see why the necessary use of land should mean that business property relief was unavailable.
In August 2017 Mr Vigne succeeded in his appeal against HMRC on the availability of business property relief (BPR) on a livery business run by his deceased mother for whom he was the executor. Unsurprisingly given...
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