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BPR qualification issues and tests

Rayney’s Tax Planning for Family and Owner-Managed Companies: 2023/24

Author:
Peter Rayney FCA, CTA (Fellow), TEP
Publisher:
Bloomsbury Professional
Publication Date:
2024
Law Stated At:
6 April 2024
Chapter 17: Succession Planning and Passing on the Family or Owner-Managed Company Qualifying and non-qualifying activities Applying the ‘mainly’ test to ‘mixed businesses’ Lessons from the Brander case HMRC informal clearance procedure for BPR ‘Qualifying’ holding companies Property development companies Holiday lets Other decided cases on investment businesses BPR restriction for excepted assets Assets used for investment business Brown’s Executors v CIR – excess cash deposits – a helpful case on future intentions Worked example of BPR on chargeable estate on death ...

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