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:
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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