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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 / I5.273A BPR and QIIPs—business or interest in a business
Commentary

I5.273A BPR and QIIPs—business or interest in a business

IHT, trusts and estates

The main category of property which attracts BPR is one of:

  1. Ìý

    •ÌýÌýÌýÌý a business or interest in a business (100% relief)1

  2. Ìý

    •ÌýÌýÌýÌý any land or building, machinery or plant which, immediately before the transfer, was used wholly or mainly for the purpose of a business carried on by the transferor and was settled property in which he was then entitled to a qualifying interest in possession (QIIP) (50% relief)2 Note that before 22 March 2006 there is no requirement that the interest in possession be a qualifying one

Business or interest in a business

An interest in a business here refers to a partnership share, although it might also refer to a case where a sole trader assigned a proportionate share of a business carried on by him as a sole trader. A partnership share is a share of assets less liabilities where the assets and the liabilities in question are defined by the agreement of the partners. There may be dispute in some cases

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Web page updated on 17 Mar 2025 13:26