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BPR and investment in family company

Ian Maston (Mastoni Tax Ltd) on how to structure an investment in a family company and whether these funds will attract business property relief.

Question

 
My client is a 90 year old individual who wishes to invest funds into the family company. He wants to know whether these funds will attract business property relief; and if so how he should structure the investment and how long he will need to wait before he becomes entitled to the relief. 
 

Answer

 
To attract business property relief it is of course imperative that the family company is mainly a trading company not an investment company. A company which is ‘wholly or mainly’ one of holding investments cannot qualify for the relief (IHTA 1984 s 105(3)). This being the case ...

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