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Trustees of David Zetland Settlement v HMRC

In Trustees of David Zetland Settlement v HMRC (TC02690 – 17 May) a trust held a leasehold interest in a commercial property and also owned eleven residential properties. The trustees appealed against a charge to IHT under IHTA 1984 s 64 contending that the properties qualified for business property relief. The First-tier Tribunal dismissed the appeal holding that the trust was carrying on a business which consisted mainly of making or holding investments within IHTA 1984 s 105(3) so that the land was not ‘relevant business property’.

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Why it matters: IHTA 1984 s 104 provides for relief from inheritance tax for the transfer of ‘any relevant business property’. IHTA 1984 s 105 defines ‘relevant business property’ and s 105(3) provides that a business does not qualify as ‘relevant business property’ if it consists wholly or mainly of making...

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