Excluded from the definition of relevant business property, and therefore from the relief, are undertakings where the business carried on consists wholly or mainly of:
- Ìý
(a)ÌýÌýÌýÌý dealing in securities, stocks or shares
- Ìý
(b)ÌýÌýÌýÌý dealing in land or buildings, or
- Ìý
(c)ÌýÌýÌýÌý making or holding investments1
Each of these is considered in more detail below. The meaning of 'wholly or mainly' is then considered.
Dealing in securities, stocks and shares
An exception to the rule against investments businesses attracting BPR is that the relief is available to market makers and discount houses carrying on business in the UK2.
A 'market maker' is defined by IHTA 1984, s 105(7) as a person who holds themselves out at all normal times in compliance with the rules of the Stock Exchange as willing to buy and sell securities, stocks or shares at a price specified by them and is recognised as doing so by the Council of the Stock Exchange.
HMRC has powers to extend the categories of business
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Web page updated on 17 Mar 2025 17:32