Maximising BPR

It is often the case that the business premises are owned outside of a limited company by the directors/shareholders usually for taxation reasons. However the potential disadvantage which is often overlooked is the loss of business property relief (BPR) for inheritance tax either wholly or partially. Somewhat nonsensically it seems to me business property relief is denied when property is owned personally by a director/shareholder and he or she does not have control of the company.

Thus when two unconnected individuals each own 50% of the issued share capital neither has control and therefore their interest in the business property owned personally by them does not attract business property relief. The fact that they jointly control the company appears to be disregarded albeit in reality this is somewhat similar to the situation where they were partners in a partnership...