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Home / Simons-Taxes /IHT, trusts and estates /Part I7 Special reliefs /Division I7.1 Business property relief (BPR) /Business property subject to contracts / I7.160 BPR and binding contracts for sale
Commentary

I7.160 BPR and binding contracts for sale

IHT, trusts and estates

I7.160 BPR and binding contracts for sale

Business property subject to a binding contract for sale is not relevant business property unless:

  1. Ìý

    •ÌýÌýÌýÌý the property is a business or an interest in a business and the sale is to a company which is to carry on the business, and the consideration consisted mainly of shares in or securities of that company1, or

  2. Ìý

    •ÌýÌýÌýÌý the property is shares in or securities of a company and the sale is made for the purpose of the reconstruction or amalgamation of the company

This provision is a safeguard for the taxpayer who is incorporating or reconstructing

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