- Offer more to pay less—business property relief and furnished holiday lets (Cox v Revenue & Customs)
- What are the practical implications of this case?
- What was the background?
- What did the court decide?
- Case details
Private Client analysis: This case concerned an appeal by the executors of Sheriff Cox’s estate of a notice of determination by HMRC which ruled that Sheriff Cox’s furnished holiday lettings business did not qualify for business property relief (BPR). The only issue for determination by the First-Tier Tax Tribunal (FTT) was whether the furnished holiday property known as Crail House was eligible for BPR. The FTT dismissed the taxpayers’ appeal and determined that HMRC was right to conclude that the furnished holiday lettings business did not qualify for BPR as it consisted mainly of making or holding of investments for the purposes of section 105(3) of the Inheritance Tax Act 1984. In coming to that conclusion the FTT provided helpful analysis of what a FTT will consider relevant in assessing whether a particular furnished holiday lettings business will qualify for BPR which may assist taxpayers in establishing what steps they need to take to put their businesses in the strongest position to qualify for BPR. Written by Mary Ashley, barrister at Old Square Tax Chambers.
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