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

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

Employment Tax

Loans provided to employees

Loans provided to employeesEmployers sometimes provide their employees with loans, sometimes charging interest and often not, either as part of the reward package or to help the individual meet significant expenditure. For example, it is common to provide loans for the purchase of annual travel

14 Jul 2020 12:11 | Produced by Tolley Read more Read more
Value Added Tax

Exemption ― burial and cremation

Exemption ― burial and cremationThis guidance note provides an overview of the VAT treatment of services that are provided in connection with the burial or cremation of human remains.VAT treatmentThe following services are exempt from VAT:•the disposal of the remains of the dead•making arrangements

14 Jul 2020 11:38 | Produced by Tolley Read more Read more
Owner-Managed Businesses

Tax implications of administration and liquidation

Tax implications of administration and liquidationThis guidance considers the tax implications of a company going into administration or liquidation.Introduction to company administration and liquidationCompany going into administrationA company which is in financial difficulty may go into

14 Jul 2020 15:29 | Produced by Tolley Read more Read more