Commentary

I7.105 HMRC advance clearance for BPR

IHT, trusts and estates

I7.105 HMRC advance clearance for BPR

I7.105 HMRC advance clearance for BPR

HMRC offers a non-statutory clearance service for business property relief (BPR) where there is material uncertainty as to the interpretation of the law.

Applicants must demonstrate the commercial significance of the transaction that causes genuine uncertainty, and can identify an aspect of the law or HMRC practice which is uncertain. HMRC will provide its view of the tax consequences of a transfer of value that, leaving aside the application of BPR, would result in an immediate inheritance tax charge and provided that the other conditions are met. Clearances in these change of ownership cases

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