Commentary

I7.371 Interaction between APR and BPR

IHT, trusts and estates

I7.371 Interaction between APR and BPR

I7.371 Interaction between APR and BPR

Agricultural property often qualifies as relevant business property or underlies assets such as company shares which so qualify.

For transfers made before 10 March 1981, it was often beneficial not to claim APR and take advantage of the BPR. For transfers made after 9 March 1981 this is not possible because APR is applied automatically by HMRC1 and IHTA 1984, s 114(1) provides that BPR is not available in relation to any value which has been reduced by APR.

There are, nevertheless, circumstances in which APR is not available in respect of agricultural property and BPR is. One example is a minority

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