BPR clearances

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 clearances
  • Introduction
  • Making the clearance application

Introduction

In many situations it will be relatively easy to determine the business property relief (BPR) status of business property. However, some cases are more complex and may give rise to a degree of uncertainty due to the subjective nature of many of the various conditions.

To provide some certainty in such difficult or borderline cases, HMRC now operates a non-statutory clearance procedure for BPR for particular contemplated transactions or events, such as a planned transfer of business property to a discretionary trust.

However, HMRC will not give clearances in hypothetical

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