Commentary

I12.503 Problems with excepted assets

IHT, trusts and estates

I12.503 Problems with excepted assets

I12.503 Problems with excepted assets

Experience has shown that HMRC Capital Taxes will seek to challenge the availability of business property relief for an asset in the balance sheet of a trading company which, in their contention, is neither used wholly or mainly for the purposes of the business nor seems likely to be required in the future in connection with that business. This attack is designed to prevent assets such as surplus cash, paintings, antiques, Rolls Royce cars and the like being put in to the balance sheet prior to a major transfer so as to enable them to

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