BPR claim fails: Estate of G Tanner v HMRC [2025] UKFTT 328 (TC) (12 March) is another in what is becoming a long line of cases about the availability of business property relief (BPR) for a holiday accommodation business. BPR is not available where a business consists wholly or mainly of the holding of investments and it is well established in law that generally speaking holding land and property is an investment activity even if the property is actively managed. It is possible for a business to fall on the other side of the line particularly when substantial services are provided with the property but the courts have made it clear that instances of this will be rare.
The taxpayer’s representative put forward an argument that the services provided did amount to a non-property business. However it does seem that the extent of these were exaggerated....
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BPR claim fails: Estate of G Tanner v HMRC [2025] UKFTT 328 (TC) (12 March) is another in what is becoming a long line of cases about the availability of business property relief (BPR) for a holiday accommodation business. BPR is not available where a business consists wholly or mainly of the holding of investments and it is well established in law that generally speaking holding land and property is an investment activity even if the property is actively managed. It is possible for a business to fall on the other side of the line particularly when substantial services are provided with the property but the courts have made it clear that instances of this will be rare.
The taxpayer’s representative put forward an argument that the services provided did amount to a non-property business. However it does seem that the extent of these were exaggerated....
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