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
imgtext

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 unquoted, ‘quoted’ means listed on a recognised stock exchange. The list of

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  • 03 Nov 2025 14:50

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