BPR on commercial property
The Trustees of David Zetland Settlement v HMRC (2013) In a First Tier Tribunal case reported on the 1st May 2013 the question of when a business consists of ‘wholly or mainly making or holding investments’ (IHTA 1984 s105(3)) was considered. A business that falls into this category will not be ‘relevant business property’ eligible for Business Property Relief (BPR) from Inheritance Tax. The David Zetland Settlement owned, amongst other things, the head lease of a 140,000 sqft commercial building in Scrutton Street, EC2. The building was divided into 53 separate units. These were let as...
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