Commentary

I12.510 Assets used by a sole trader

IHT, trusts and estates

I12.510 Assets used by a sole trader

I12.510 Assets used by a sole trader

It is not only the transfer of a business itself which will attract business property relief. The decision in Re Nelson Dance Family Settlement; Revenue and Customs Comrs v Trustees of the Nelson Dance Family Settlement [2009] EWHC 71 (Ch), [2009] STC 802 made it clear that transfers of mere assets used in the business of a sole trader can attract BPR at 100%, as well as transfers of the business itself. This is because the relief applies where the value transferred is attributable to the value of relevant business property. The value

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