Commentary

I7.181 Interaction between BPR and APR

IHT, trusts and estates

I7.181 Interaction between BPR and APR

I7.181 Interaction between BPR and APR

Agricultural property often qualifies as relevant business property or underlies assets such as company shares which so qualify. Agricultural relief is given in priority — IHTA 1984, s 114(1) provides that BPR is not available in relation to any value which has been reduced by agricultural property relief.

There are, nevertheless, circumstances in which APR is not available in respect of agricultural property and BPR is. One example is a minority holding of shares in a farming company in respect of which there can be no agricultural relief, but BPR can be available at

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