inheritance tax – Page 2 – Charles Cooper

Beresford (Dec’d) v. HMRC [2024] UKFTT 952 (TC)

The frequency of transactions for serviced office lets were ‘clearly not analogous to a hotel business’ and the business amounted to ‘wholly or mainly making or holding of investments’ for Inheritance Tax Business Property Relief: https://caselaw.nationalarchives.gov.uk/ukftt/tc/2024/952

Demetriou & Anor v. HMRC [2024] UKFTT 830 (TC)

A managed chalk stream trout fishery ‘was mainly a business of holding investments’ and does not benefit from Inheritance Tax Business Property Relief under s.104 ITA 1984: https://caselaw.nationalarchives.gov.uk/ukftt/tc/2024/830

Butler & Ors v. HMRC [2023] UKFTT 00872 (TC)

Where catering is provided by a separate business, a wedding venue is ‘predominantly for the purpose of holding its property as an investment’ and Business Property Relief does not apply for Inheritance Tax purposes: https://caselaw.nationalarchives.gov.uk/ukftt/tc/2023/872

Charles Cooper | Barrister & Mediator

Category: inheritance tax