Commentary

I7.161B BPR and relevant property trusts

IHT, trusts and estates

I7.161B BPR and relevant property trusts

I7.161B BPR and relevant property trusts

Business property relief (BPR) operates as a reduction in the value transferred1. For the purposes of BPR, references to a transfer of value include references to occasions of charge on settled property subject to the relevant property rules2 References to the value transferred are treated as references to the amount on which IHT is chargeable and references to the transferor include references to the trustees3.

This means that in contrast to qualifying interests in possession, the availability of BPR is judged by regarding the trustees as the owners of any of the settled property

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