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Investment properties

Agricultural, Business and Heritage Property Relief

Chris Erwood CTA, ATT, TEP
Bloomsbury Professional
Publication Date:
September 2023
Law Stated At:
September 2023

Simply put, the direct holding of mere investments in whatever format does not qualify for BPR and the long-term solution may be the creation of a nil rate band discretionary trust of the investments, holding over any gain into the trust (assuming the settlor-interested rules are not contravened). However, the holding of investments through the medium of a subsidiary of a group of companies could provide access to relief, but this stratagem is not without risk and the interaction of IHTA 1984, ss 110 and 112 must be carefully observed (see Chapter 8).