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The Personal Representatives of the Estate of M W Vigne v HMRC

In The Personal Representatives of the Estate of M W Vigne v HMRC [2017] UKFTT 632 (15 August 2017) the FTT found that a large piece of land on which a horse livery business was conducted was not held as part of a business consisting in the holding of investments (IHTA 1984 s 105(3)) so that business property relief applied (s 116).

At the time of her death Mrs Vigne had been the sole owner of 30 acres of land which comprised stables. She had not lived on the land. Her personal representatives had claimed business property relief but HMRC had denied the relief on the ground that the business was excluded under s 105(3) as it consisted mainly of holding investments. It contended that if a livery business is being operated which necessitates land being available for it to be viable that is...

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