Land, buildings, machinery or plant ('land etc') which, immediately before the transfer, was used wholly or mainly for the purposes of a business carried on by a company controlled by the transferor or by a partnership of which the transferor was then a partner1, will qualify for BPR at 50%2, assuming that all of the other conditions (see I7.104) are met.
Whether the land etc is used for the purposes of the business is a factual test and there does not have to be a binding contractual relationship between the transferor and the company or partnership3.
Limited liability partnerships are treated as partnerships for BPR purposes and it is expressly provided that occupation or use of property
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Web page updated on 17 Mar 2025 17:31