Commentary

I7.170 BPR on property subject to a reservation

IHT, trusts and estates

I7.170 BPR on property subject to a reservation

Gifts with reservation and other aspects

I7.170 BPR on property subject to a reservation

This article examines the availability of business property relief (BPR) on assets that are subject to the gifts with reservation of benefit rules. For further information on these rules generally see Division I3.4

Where an IHT charge arises on property subject to a reservation at the donor's death, or which ceased to be subject to a reservation within seven years of the donor's death, the availability of BPR is (subject to certain rules), determined as if the occasion of charge were a transfer of value by the donee.

This is so if the property subject to

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