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Home / Simons-Taxes /IHT, trusts and estates /Part I5 Settled property /Division I5.3 Settlements within the relevant property regime /Relevant property settlements—miscellaneous points / I5.373 BPR and APR for relevant property trusts
Commentary

I5.373 BPR and APR for relevant property trusts

IHT, trusts and estates

Business property relief (BPR) (see Division I7.1) is expressly made applicable to settlements without a qualifying interest in possession (QIIP)1. The legislation provides that references in the BPR provisions to a transfer of value include references to an occasion of IHT charge under the rules for settlements without a qualifying interest in possession. Additionally, references in the BPR provisions to the value transferred by a transfer of value include references to the amount on which tax is chargeable under the rules for such settlements, and references to the transferor include references to the trustees of the settlement.

Note that this includes not only exit and periodic charges (as described in this Division), but also the charge on property leaving certain kinds of favoured trust (for which see Division I5.6).

There is an exception in the case of a charge under IHTA 1984, s 79 (for conditionally exempt works of art etc in certain circumstances — see I7.520).

Agricultural property relief (APR) (see Division I7.3) is similarly made expressly applicable to settlements

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Web page updated on 17 Mar 2025 17:19