My client is a holding company which carries on a mixture of activities; it carries on both trading and investment activities on its own account and also acts as a holding company of two trading subsidiaries. The company’s activities as a whole can be analysed by reference to turnover profits and management time as approximately 40% trading 20% investment and 40% acting as the holding company of a trading group. Will IHT business property relief be available on a chargeable transfer of the holding company’s shares? If not what can be done to improve the position?
Business property relief (BPR) reduces the taxable value of a chargeable transfer of ‘relevant business property’ by either 100% or 50%. The 100% rate applies broadly to...
