Wedding barn does not qualify for business property relief for

A limited liability partnership (LLP) carried out the following activities: farming lettings and weddings of which the latter was the largest. On the death of Mrs Butler a member of the LLP a dispute arose as to whether inheritance tax business property relief was available.

HMRC said it was a business that could be characterised as wholly or mainly holding investments falling within the investment exclusion (IHTA 1984 s 106 ) but the taxpayers argued it was a package of services and facilities provided by the LLP and therefore qualified for BPR.

The First-tier Tribunal concluded that the business carried fell on the investment side of the line: most of the activities were no more than would be provided by a person letting out the property. Indeed a third party undertook many of the functions of the LLP such as bookings and...