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Subsequent decisions on s 105(3)

Agricultural, Business and Heritage Property Relief

Chris Erwood CTA, ATT, TEP
Bloomsbury Professional
Publication Date:
September 2023
Law Stated At:
September 2023
Chapter 9: Relevant business property: exceptions to the relief: ‘wholly or mainly holding investments’ Hall v CIR The Pearce case Furness: a victory for the taxpayer Weston v IRC Stedman’s Executors v IRC; CIR v George and Another Review of the law in the light of George Holiday lettings Holiday lettings: Pawson, Green, Ross and Cox Livery business: Vigne v HMRC Mixed use estate: Farmer v IRC The Earl of Balfour’s case Moneylending: the Phillips case The case serves as a reference point for advisers. Commonly an elderly entrepreneur may be happy to give up the active cut and thrust of daily commerce to his children but might still be happy to support their activities by providing finance, even though that may involve him in significant commercial risk. However, a note of caution – BPR cannot be garmented and access will very much depend on the facts of each case. ...

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