I7.110 Meaning of business
The first step when considering whether BPR can apply is that there has to be a business. For these purposes, a business includes a business carried on in the exercise of a profession or vocation, but does not include a business carried on otherwise than for gain1. Though IHTA 1984, ss 105(1)(b), (bb) and (cc) do not say that the company concerned must be carrying on a business, this is implicit in the section as a whole2.
There is no territorial limit on the location of the business, other than in respect of market makers and discount houses3.
Otherwise than for gain
A consistently loss-making enterprise was held not to qualify for BPR as it was carried on otherwise than for gain in Grimwood-Taylor v IRC4. The land was principally purchased for occupation by the shareholders
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