What is Business Property Relief (BPR)? When does it apply? What are the conditions?

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This is a freeview 'At a glance' guide to Business Property Relief.

At a glance

Business Property Relief (BPR) provides relief from Inheritance Tax (IHT) on the transfer of relevant business assets at a rate of 50% or 100%.

Relevant business property comprises:

Type Rate of relief

A business or an interest in a business.

100%

Unquoted shares, including shares listed on the Alternative Investment Market (AIM).

100%

Unquoted securities which on their own or combined with other unquoted shares or securities give control of an unquoted company.

100%

Quoted shares which give control of the company.

50%

Land or buildings, machinery or plant used wholly or mainly for the purposes of the business carried on by a company or partnership.

50%

Land or buildings, machinery or plant available under a life interest and used in a business carried on by the beneficiary.

50%


Relevant property must be held for at least two years in order to qualify for relief.

Pitfalls and planning points

Sole traders

Partners

Directors

Business activities

BPR is not available in respect of a business, or shares in a company that is:

There is no BPR if the business or company is one of 'wholly or mainly' in dealing in securities, stocks or shares, land or buildings or in the making or holding of investments.

There is a wealth of case law on the topic of 'wholly or mainly'. See IHT Business Property Relief for an analysis of the points to consider. 

A business that only generates investment income will not attract BPR, so this excludes:

Some business activities are borderline and whether they will qualify for relief depends on the nature of services provided, typically these include:

Certain activities are regarded as trading:

Useful guides on this topic

IHT Business Property Relief
A guide to what Business Property Relief is and when it can apply and pitfalls and planning points.

IHT Agricultural Property Relief 
What is Agricultural Property Relief (APR)? When does it apply? What are the conditions and restrictions of the relief?

Woodlands: Overview
Woodlands and forestry ownership carry significant tax reliefs, including Income Tax, Capital Gains Tax (CGT) and Inheritance Tax (IHT). This is a guide to those reliefs. 


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