½Û×ÓÊÓƵ

I7.120 Value of a business or interest in a business

IHTA 1984, s 110 provides that for the purposes of business property relief (BPR):

1. Ìý

   •ÌýÌýÌýÌý the value of a business or interest in a business is taken to be its net value

2. Ìý

   •ÌýÌýÌýÌý the net value of a business is the value of the assets used in the business (including goodwill) reduced by the aggregate amount of any liabilities incurred for the purposes of the business

3. Ìý

   •ÌýÌýÌýÌý in ascertaining the net value of an interest in a business, assets or liabilities other than those by reference to which the net value of the entire business would fall to be ascertained, are ignored¹

The predecessor of this provision² was discussed in Fetherstonaugh v IRC³. It was held that, in determining the value of a sole trader's business, every asset owned or deemed to be owned by the sole trader which is used in the business and included in the transfer of