½Û×ÓÊÓÆµ

BPR ― application to groups of companies

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance

BPR ― application to groups of companies

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance
imgtext

This guidance note explains how BPR applies to holding companies and to groups of companies. Without special provision, a holding company would not qualify for BPR as it is not in its own right a trading company and this guidance note covers how and when a holding company will qualify. It also considers the approach to be taken to a group scenario when assessing the BPR status of a shareholding. This covers the assessment of the trading status of the group first and then of each individual subsidiary. If a subsidiary is not a trading company in its own right then its value is disregarded. It consolidates and links to the guidance in this area, much of which is included in various correspondence between HMRC and the professional bodies.

Basic principles

Unquoted shares, quoted shares or securities from a controlling holding or unquoted securities from a controlling holding fall into the categories of property which can qualify for BPR. See the BPR ― relevant business property guidance note for further information.

However,

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, and tax research, register for a free trial of Tolley+â„¢
Powered by

Popular Articles

What are connected companies for loan relationship purposes ― practical approach

What are connected companies for loan relationship purposes ― practical approachBrief overview of the rulesThe loan relationships legislation applies to any ‘money debt’ arising from the lending of money entered into by a company, either as a lender or borrower. The rules are contained in CTA 2009,

20 Apr 2021 16:00 | Produced by Tolley Read more Read more

Research and development (R&D) relief ― overview

Research and development (R&D) relief ― overviewThis guidance note provides an overview of the research and development (R&D) tax reliefs for companies.See the Research and development tax relief summary diagram which summarises the R&D tax relief.See also Simon’s Taxes D1.401.For a factsheet which

14 Jul 2020 12:22 | Produced by Tolley in association with Will Sweeney Read more Read more

Exemption ― insurance ― overview

Exemption ― insurance ― overviewThis guidance note provides an overview of the VAT treatment of insurance products and should be read in conjunction with the Insurance ― specific transactions and Exemption ― insurance ― brokers and agents guidance notes.Is insurance exempt from VAT?Supplies of

Read more Read more