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HMRC v The personal representatives of the estate of M Vigne

In HMRC v The personal representatives of the estate of M Vigne [2018] UKUT 357 (31 October 2018) the UT found that business property relief (BPR) (under the Inheritance Tax Act (IHTA) 1984 s 105) applied to a livery business.

The issue was whether the livery business of the late M. Vigne consisted wholly or mainly of making or holding investments so that it was not ‘relevant business property’ for the purpose of BPR. HMRC contended that the FTT had misapplied the statutory test in particular because part of the FTT’s decision did not include references to the ‘wholly and mainly’ test of s 105(3).

The UT found however that the FTT had fully in mind the ‘wholly or mainly’ test referring to the FTT’s final conclusions in which it explicitly addressed the point when finding that it was ‘the provision of enhanced...

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