Commentary

I7.368 Partnerships and agricultural tenancies

IHT, trusts and estates

I7.368 Partnerships and agricultural tenancies

I7.368 Partnerships and agricultural tenancies

An interest in a partnership is entitled to APR to the extent that the value transferred is attributable to agricultural property. In allocating liabilities between the agricultural and non-agricultural assets of the partnership, debts charged on specific property (such as mortgages) are set against that property but HMRC practice1 is to set unsecured debts primarily against non-agricultural property (which increases the APR but does, of course, have the effect of reducing the value of the other assets for the purposes of any BPR).

Secured charges are apportioned rateably between agricultural value and non-agricultural value (for

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