A transfer of value of 'a business or an interest in a business' will qualify for relief at 100%1. This includes sole traders, interests in partnerships and interests in LLPs.
The business or individual assets
It was commonly understood for many years that for BPR purposes relevant business property under this heading meant the whole of a business rather than any individual assets and liabilities.
However, it was established in the case of Nelson Dance that a transfer of value consisting of a lifetime gift of an asset of a business can qualify for the relief, even though that asset taken by itself is not relevant business property2. A transfer of value is a disposition which causes a loss to the estate of the transferor3, and BPR applies where the value transferred is attributable to relevant business property. This is the case
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Web page updated on 17 Mar 2025 17:25