Mark McLaughlin points out one of the ways in which inheritance tax business property relief can be lost, and how it might be preserved.
Business property relief (BPR) offers relief from inheritance tax (IHT) of 100% (or 50%) on a transfer of value which is attributable to ‘relevant business property’.
Unfortunately, not all unquoted company shares qualify for BPR. Certain company activities make the shares ineligible for relief, such as dealing in stocks or shares, land or buildings, or making or holding investments (IHTA 1984, s 105(3)). These exclusions are subject to only limited exceptions (in s 105(4), (4A)).
However, let us take the example of a single unquoted trading company, which is not carrying on an excluded activity.
Exception to the rule
Perhaps unsurprisingly, the BPR legislation
