BPR and debt

By Tolley in association with Peter Rayney of Peter Rayney Tax Consulting Ltd
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The following Trusts and Inheritance Tax guidance note by Tolley in association with Peter Rayney of Peter Rayney Tax Consulting Ltd provides comprehensive and up to date tax information covering:

  • BPR and debt
  • Deduction of liabilities
  • Business loans

Deduction of liabilities

When determining the value of a sole trader business, interest in a partnership or limited liability partnership IHTA 1984, s 110 provides that the value of the business (or interest in the business) must be reduced by all liabilities secured on it, or incurred for the purposes of the business.

In addition, liabilities secured on individual assets reduce the value of those assets for IHT purposes. In the context of BPR, this rule is likely to be relevant when looking at eligible shares or property held outside the company or partnership.

IHTA 1984, s 162

If a business asset qualifies for BPR, the deduction of liabilities offers no inheritanc

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