PM60450 - Indirect, capital and transfer taxes and other tax obligations: Inheritance Tax (IHT): Business Property Relief
Business Property Relief (BPR) reduces the value transferred by a transfer of value to the extent that it is attributable to 바카라 사이트˜relevant business property바카라 사이트™ (IHTA 1984/S104).
BPR is available at 100% on property consisting of a business or an interest in a business, which can include a partner바카라 사이트™s share in a partnership business (see IHTM25152). However, no BPR will be allowed where the business consists wholly or mainly of making/holding investments or dealing in securities, stocks/shares or land/buildings.
Where BPR (at 100%) is available on the partnership interest, BPR at 50% is also available on any land and buildings or plant and machinery owned by a partner but used wholly or mainly for the purposes of the partnership바카라 사이트™s business.
For the transfer of value to attract BPR, the relevant business property must have been held by the transferor throughout the period of two years immediately preceding the transfer. Where a traditional partnership incorporates itself as an LLP, a partner바카라 사이트™s period of ownership for the purposes of qualifying for BPR is not interrupted (further guidance is available at IHTM25094).