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Home / Simons-Taxes /IHT, trusts and estates /Part I5 Settled property /Division I5.2 Settlements with a qualifying interest in possession (QIIP) /Application of APR and BPR to QIIPs / I5.272 APR, BPR and QIIPs—ownership

I5.272 APR, BPR and QIIPs—ownership

IHT, trusts and estates

The relevant property must have been owned by the transferor continuously for seven years for APR¹ and two years for BPR².

Meaning of ownership

The person entitled to a QIIP (the life tenant) is regarded as beneficially entitled to the property in which the interest subsists³.

The legislation does not refer to ownership, but it seems to have the effect of treating a life tenant as the owner of it for APR and BPR

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I7.333A Companies and replacement APR property

B3.325 General exclusions—first-year qualifying expenditure

A4.204 Claims procedure—corporation tax

B5.301 Intellectual property—overview

I4.142A Liabilities which are not discharged out of the estate

B3.340A Hire purchase of plant and machinery and similar contracts

A1.543 Welsh GAAR

E1.1502 Tax treatment of transfers with accrued interest

I5.251 Absolute entitlement by the life tenant

B2.315 The concept of wholly and exclusively

C3.304 Rollover relief—expenditure on replacement assets qualifying for relief

C3.305 Rollover relief—time limit for acquisition of replacement assets

C1.511 Use of Mansworth v Jelley losses

C3.1705 Non-qualifying tax years, and disposals of a main home under NRCGT

B5.846 Charities and close companies

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

B2.472 Tax and tax-related expenditure

B2.202 Capital receipts

D6.233 Rights issue—sale of rights nil paid

I5.1304 Beneficiary with contingent interest