Application of BPR and APR to non-UK property

Copyright © 2025 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 © 2025 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

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
TAKE A FREE TRIAL NOW
Powered by Tolley+™
  • 03 Nov 2025 14:50

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

Popular Articles

Owner-Managed Businesses

Trade or hobby

Trade or hobbyInteraction of hobby farming rules and commercialityFarming has its own set of ‘hobby farming rules’, which historically have stated that a profit must be made every six years. This is known as ‘the five-year rule’, in that there can be five years of losses but there must be a profit

14 Jul 2020 13:50 | Produced by Tolley Read more Read more
Employment Tax

Incentives, awards and prizes

Incentives, awards and prizesIntroduction ― incentives, awards and prizesEmployers may use a variety of methods to reward and encourage employees in their work. These are commonly known as incentives, awards or prizes. For the purposes of this note, the term ‘award’ will be used to cover all

14 Jul 2020 11:57 | Produced by Tolley Read more Read more
Value Added Tax

Reverse charge ― buying in services from outside the UK

Reverse charge ― buying in services from outside the UKThis guidance note covers the reverse charge that applies to services that have been bought in from outside the UK. For an overview of VAT and international services more broadly, see the International services ― overview guidance note. For

15 Dec 2020 14:02 | Produced by Tolley Read more Read more