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 APR and BPR. Sometimes APR and BPR may be available on the same assets and sometimes only one relief may be available. This 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.

APR and BPR 100% rate cap

From 6 April 2026, the 100% rate of relief for BPR and APR will be restricted. 100% relief will only be available on the first £1m of relievable property and any value in excess of this will be relieved at 50%. See

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

Spouse exemption from inheritance tax

Spouse exemption from inheritance taxArguably, the most important inheritance tax exemption is the spouse exemption from inheritance tax.There is no IHT to pay on gifts from husband to wife and vice versa, or from one civil partner to the other (referred to collectively in this note as ‘spouses’).

14 Jul 2020 13:56 | Produced by Tolley in association with Emma Haley at Boodle Hatfield LLP Read more Read more

Double tax relief

Double tax reliefWhen income arises in a foreign country to a UK resident company and that income is taxable in that foreign country, the UK may give the company relief for the foreign tax by crediting the foreign tax against the UK tax charged on that income. This might include withholding tax on

14 Jul 2020 11:31 | Produced by Tolley Read more Read more

Non-trading deficits on loan relationships

Non-trading deficits on loan relationshipsOverview of non-trading deficits (NTDs)When a company’s debits on its non-trading loan relationships and derivative contracts in an accounting period exceed the credits on its non-trading loan relationships and derivative contracts in the same period (the

14 Jul 2020 12:17 | Produced by Tolley Read more Read more