Commentary

I5.273 APR and QIIPs — interest of the transferor

IHT, trusts and estates

I5.273 APR and QIIPs — interest of the transferor

I5.273 APR and QIIPs — interest of the transferor

The main circumstance in which 100% APR is available is where the interest of the transferor immediately before the transfer carried the right to vacant possession or the right to obtain it within the next 12 months.

It seems to be the case, and to be accepted by HMRC, that a qualifying interest in possession (QIIP) in vacant possession agricultural land qualifies the land for 100% relief on the termination of that interest.

A legal technicality exists whereby the vacant possession attaches to the legal interest in the land, but the

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial