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Background

This Division examines the reliefs available for property comprised in what is collectively known as the national heritage, namely works of art, historic houses and other property of sufficient public interest to qualify to form part of the national heritage.

HMRC has produced extensive guidance on this topic (and others), primarily contained in its document Capital Taxation and the National Heritage.

This form of relief was first introduced for estate duty purposes¹, and when that duty was abolished in favour of CTT the relief was retained in a modified form². The CTT relief when CTT was first introduced applied only to charges arising on death (see I7.521, I7.522). An extended and revised form of relief was introduced a year later in respect of transfers made after 6 April 1976. This gives conditional exemption in appropriate circumstances to heritage property which is