Ian Maston outlines how the IHT business property relief rules apply to groups of companies and similar structures
Background: the BPR basicsBPR is available at 100% in relation to property consisting of a business or interest in a business - which would include the partnership interest of a partner – and in relation to shares in an unquoted company.
BPR is specifically denied however where the business carried on consists wholly or mainly of the making or holding investments (IHTA 1984 s 105(3)).
It is not the purpose of this article to outline how the courts and tribunals have identified what constitutes ‘investment’; however the paradigm case is that of letting land in return for a rental...
