Commentary

I5.274 BPR and QIIPs—securities or quoted shares

IHT, trusts and estates

I5.274 BPR and QIIPs—securities or quoted shares

I5.274 BPR and QIIPs—securities or quoted shares

One of the categories of business property relief (BPR) is on securities or quoted shares of or in a company, to which a transfer of value is attributable, which (either by themselves or together with other such shares or securities owned by the transferor) gave the transferor control of the company immediately before the transfer1 — see I7.102.

It seems that for this purpose the transferor can, by virtue of IHTA 1984, s 49(1), aggregate shares which he owned absolutely with ones in which he had an interest in possession, even though the

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