Other cases that caught our eye 27 October 2023

Business property relief: E Butler and others v HMRC [2023] UKFTT 872 (TC) (27 September 2023) revisits the familiar territory of whether a business was one of wholly or mainly of holding investments: such businesses do not qualify for IHT business property relief. The dispute here was over a weddings business carried out on a farm. On a review of the evidence and the case law the FTT 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. The business did not provide the catering: that was done by an outside company who contracted directly with the bride and groom themselves. The summary at para 147 is a useful place to start: there the judge summarised the key tests for BPR and assessed the businesses activities against each of...