Interaction of APR and BPR

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance

Interaction of APR and BPR

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance
imgtext

This guidance note considers the interaction of agricultural property relief (APR) and business property relief (BPR). Sometimes APR and BPR may be available on the same assets and sometimes only one relief may be available. This guidance note considers which relief will apply and which assets may not qualify. A farming business or landed estate may qualify for relief in its entirety by using BPR to ‘mop up’ the excess value, even where it holds assets that do not qualify for APR in their own right. Shares in farming companies may qualify for BPR rather than APR, or neither relief if the land is let. Consideration is also given to the replacement of assets for BPR purposes where assets qualifying for APR are replaced with assets qualifying for BPR or vice versa.

100% relief allowance and 100% trust relief allowance

From 6 April 2026, the 100% relief allowance and 100% trust relief allowance restrict 10% relief to £2.5 million of relievable property, and any value in excess of this will be relieved

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Powered by Tolley+

Popular Articles

Wholly and exclusively

Wholly and exclusivelyFor both income tax and corporation tax purposes, one of the fundamental conditions that must be satisfied for an item of expenditure to be deductible, is that it must incurred ‘wholly and exclusively’ for the purposes of the trade, profession or vocation. References to CTA

14 Jul 2020 14:00 | Produced by Tolley Read more Read more

Allowable deductions for employee-related expenses

Allowable deductions for employee-related expensesThis guidance note covers the tax treatment of some common types of trading expenditure relating to employees. Some of these are disallowable under general principles, for example the wholly and exclusively test or capital versus revenue expenditure.

14 Sep 2022 09:49 | Produced by Tolley Read more Read more

Research and development expenditure credit (RDEC)

Research and development expenditure credit (RDEC)This guidance note provides information on how research and development expenditure credits (RDEC) are calculated and utilised. The Qualifying expenditure for R&D tax relief guidance note provides information on what expenditure qualifies for

14 Jul 2020 13:24 | Produced by Tolley in association with Will Sweeney Read more Read more