Commentary

I12.508 Partnership interests

IHT, trusts and estates

I12.508 Partnership interests

I12.508 Partnership interests

Provided the partnership is a trading partnership, business property relief of 100% will be available no matter what size of interest in the partnership.

Although the position was unclear for some years it is now accepted by HMRC that the transfer of part of a capital account may amount to an interest in the business (and not solely an asset used in the business) so as to attract 100% business property relief. HMRC say that the question whether a transfer from a partner's capital account in the partnership qualifies for business relief at the time of the transfer

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