Commentary

I7.150C BPR and successive transfers example

IHT, trusts and estates

I7.150C BPR and successive transfers example

I7.150C BPR and successive transfers example

Example

X, Y and Z were equal partners in a partnership formed on 1 January 2014.

G purchased Z's one-third share on 1 January 2016.

X purchased Y's one-third share on 1 June 2016.

X died on 1 January 2017 leaving his two-thirds share to G. His original one-third share qualified for business property relief.

On 1 June 2017 G gives the whole business to his son. G dies on 19 September 2017, and the gift to G's son becomes a chargeable transfer. G's son has retained the business until G's death and it remains relevant business property apart

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