Trusts and Inheritance Tax

BPR and debt

Produced by Tolley
  • 22 Dec 2021 18:41

The following Trusts and Inheritance Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • BPR and debt
  • Deduction of liabilities
  • Business loans

BPR and debt

Deduction of liabilities

When determining the value of a sole trader business, interest in a partnership or limited liability partnership IHTA 1984, s 110 provides that the value of the business (or interest in the business) must be reduced by all liabilities secured on it, or incurred for the purposes of the business.

In addition, liabilities secured on individual assets reduce the value of those assets for IHT purposes. In the context of BPR, this rule is likely to be relevant when looking at eligible shares or property held outside the company or partnership.

If a business asset qualifies for BPR, the deduction of liabilities offers no inheritance tax advantage because the business property is already fully relieved. There would be a clear advantage in attaching liabilities to taxable assets rather than relieved assets by selecting taxable assets as

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