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02 December 2024
Business property relief
I would be grateful for readers’ views on the availability of business property relief (BPR) for IHT in the below instances.
- A trading limited company whose business includes income from consulting and income from commercial and residential let properties. While on turnover the income from trading activity is about 40-50% the balance sheet shows 85% or more of net assets are predominantly from investment activity. Though the business has been long established any value of shares attributable to goodwill developed from trading is likely to be low.
- What is the position of a minority shareholder who is also a director in a trading company whose activity and assets are wholly derived from trading activity? The shareholder holds 30% of ordinary shares. Would they be eligible even though they do not have predominant control of the business?
Query 20 431 – Investor.
Could IHTA 1984 s 105(3) apply?...
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