Application of BPR and APR to non-UK property

Copyright © 2026 LexisNexis
Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance

Application of BPR and APR to non-UK property

Copyright © 2026 LexisNexis
Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance
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This guidance note discusses the application of BPR and APR to property which is not situated in the UK.

BPR ― application to non-UK property

For an overview of BPR, see the Understanding BPR ― overview guidance note which signposts to other detailed notes on various aspects of BPR.

BPR has no territorial limitation, and BPR will apply to non-UK assets in the same way as UK assets.

The only territorial oddity is that a business which is wholly that of a market maker and which is carried on in the UK or EEA is not treated as an investment business.

When considering whether a share or security is quoted or

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  • 03 Nov 2025 14:50

Home/ Tolley Tax Guidance/ Trusts and Inheritance Tax / Advising on offshore matters

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