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Chapter 13: Planning the best use of APR and BPR for inheritance tax

Tax Planning for Farm and Land Diversification

Julie Butler (FCA)
Bloomsbury Professional
Publication Date:
Law Stated At:
11 July 2023
Too valuable to put at risk Agricultural value When and where does APR apply? Interaction of agricultural property relief (APR) and business property relief (BPR) What is a ‘failed potentially exempt transfer’ (PET)? Farming for the environment and set-aside land Farmer (Farmer’s Executors) v IRC Do Farmer and Balfour still apply? Marquess of Hertford (Dec’d) – Net value of the entire business Prosser v IRC (Lands Tribunal) Earl of Balfour – ‘investment business’ Vigne and holding investments Firth, the portfolio of evidence and the trading spectrum The Gill case in the context of APR/BPR planning More dispute cases – Guest The importance of APR/BPR and farm succession planning The OTS and APPG impact on farm succession planning Dealing with a ‘living farm business’ on death ...

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