Commentary

I5.373 BPR and APR for relevant property trusts

IHT, trusts and estates

I5.373 BPR and APR for relevant property trusts

I5.373 BPR and APR for relevant property trusts

Business property relief (BPR) (see Division I7.1) is expressly made applicable to settlements without a qualifying interest in possession (QIIP)1. The legislation provides that references in the BPR provisions to a transfer of value include references to an occasion of IHT charge under the rules for settlements without a qualifying interest in possession. Additionally, references in the BPR provisions to the value transferred by a transfer of value include references to the amount on which tax is chargeable under the rules for such settlements, and references to the transferor include references to the trustees of the settlement.

Note that this includes not only exit and periodic charges (as described in this Division), but also the charge on property leaving certain kinds of favoured trust (for which see Division I5.6).

There is an exception in

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