Commentary

I5.272 APR, BPR and QIIPs—ownership

IHT, trusts and estates

I5.272 APR, BPR and QIIPs—ownership

I5.272 APR, BPR and QIIPs—ownership

The relevant property must have been owned by the transferor continuously for seven years for APR1 and two years for BPR2.

Meaning of ownership

The person entitled to a QIIP (the life tenant) is regarded as beneficially entitled to the property in which the interest subsists3.

The legislation does not refer to ownership, but it seems to have the effect of treating a life tenant as the owner of it for APR and BPR purposes4.

Someone with an interest in possession in the residue of an unadministered estate is treated as having an interest in possession in

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