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Cash and property in a trading business

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Relief interaction

It is too simple an assumption that property or cash which does not form part of the ‘trading’ assets of a trading company or corporate group will always prejudice the key trading business reliefs for its shareholders.

Inheritance tax business property relief (BPR) and capital gains tax holdover relief and business asset disposal relief (BADR) do not necessarily work in the same way.

This article considers a confectionary business called Chocolat Ltd. Its proprietor and sole shareholder Vianne is considering her future plans around inheritance tax sale and the possible gift of some or all of her shares to her daughter Anouk. See Assets of Chocolat Ltd.

Inheritance tax

Vianne wants to understand if her business will carry an inheritance tax liability on her death when her shares will pass to Anouk. The requirement of IHTA 1984 s...

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