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Gill and grazing
Key points
- Agricultural property relief was granted on land that at first sight was let for grazing.
- Was the farmhouse ‘agricultural property’ within IHTA 1984 s 115(2)?
- Were the house and farm buildings occupied ‘for the purposes of agriculture’?
- The grazing agreements did not reflect the real activities being undertaken.
- The view of the ‘intelligent businessman’ the spectrum of land-based businesses and the concept of ‘looking at the business in the round’.
- Advisers should not assume that all land under grazing agreements will qualify for inheritance tax relief as a consequence of the Gill decision.
The Thomas Gill case (see William Charnley & Maxwell Hodgkinson as Executors of the Estate of Thomas Gill (deceased) (TC7425)) concerned the application of both agricultural property relief (APR) and business property relief (BPR) to the estate of 79 year old Mr Gill who died in November 2013.
Mr Gill...
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