The following Trusts and Inheritance Tax guidance note by Tolley in association with Elizabeth Norton at Russell-Cooke Solicitors provides comprehensive and up to date tax information covering:
The Finance Act 2009 amended IHTA 1984 in order to extend APR for UK inheritance tax to the European Economic Area (EEA). It had hitherto only applied in relation to agricultural property in the UK.
BPR is available in relation to relevant business property situated anywhere in the world.
APR provides relief on UK inheritance tax payable on lifetime transfers or on death. The relief will be either 50% or 100% of the UK inheritance tax payable on the agricultural value of the property. In order for a property to qualify for relief at 100%, it is necessary for one of three conditions to be satisfied:
All other properties which qualify for APR will be subject to relief at 50%.
It should be noted that the agricultural value is not necessarily the market value and BPR, which could often apply to the same property as APR, may well provide a greater tax saving.
See the Agricultural value and development value guidance note and other notes in the APR Planning sub-topic.
APR was extended to the EEA following a press release by the European Commission stating that it did not consider the legislation to be compatible with the free movement of capital.
The extension to the EEA came into effect on 22 April 2009
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