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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 / I5.273 APR and QIIPs—interest of the transferor
Commentary

I5.273 APR and QIIPs—interest of the transferor

IHT, trusts and estates

The main circumstance in which 100% APR is available is where the interest of the transferor immediately before the transfer carried the right to vacant possession or the right to obtain it within the next 12 months.

It seems to be the case, and to be accepted by HMRC, that a qualifying interest in possession (QIIP) in vacant possession agricultural land qualifies the land for 100% relief on the termination of that interest.

A legal technicality exists whereby the vacant possession

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Web page updated on 17 Mar 2025 17:01