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Anne Christine Curtis Green v HMRC

In Anne Christine Curtis Green v HMRC [2015] UKFTT 236 (21 May 2015) the FTT held that a holiday letting business did not qualify for business property relief (BPR).
 
Mrs Green ran a holiday letting business. She had transferred 85% of the business to a settlement (the trust) and the issue was whether the transfer qualified for 100% BPR under IHT 1984 ss 104 and 105. 
 
Applying George [2003] EWCA Civ 1763 and Pawson [2013] UKUT 50 the FTT found that a number of Mrs Green’s activities were investment activities including marketing pricing booking accommodation dealing with complaints and requests insurance repairs and maintenance. The extra services provided (such as cleaning) were both relatively minor and ancillary to the provision of the accommodation. 
 
Furthermore ...
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