Two unmarried sisters have lost their appeal in the European Court of Human Rights (ECHR) against the need to pay inheritance tax.
Joyce and Sybil Burden, who are both in their 80s, inherited the Wiltshire house they currently share, upon the death of their father around 30 years ago. It is believed to be presently worth £875,000.
The Burdens made wills expressing their intention that the first of them to die would leave her entire estate to the other, incurring an IHT liability of around £25,000 under the latest rules.
The two spinsters then claimed to the ECHR that as sisters living together they were discriminated against, compared to a married couple or civil partners, because IHT on half the value of their home would be due on the death of the first sister.
In September 2006, the Burdens lost their substantive claim in the Strasbourg court that they should be entitled to the same exemption as a married or civil partnership couple.
However, they were granted permission to an appeal, at which the judges found by an overwhelming majority that the sisters' relationship was of a different nature to that of married couples or homosexual partners.
As such, said the court, the Burdens had not suffered discrimination, and there was no violation of the European Convention on Human Rights.
The judgment stated: 'The absence of… a legally binding agreement between the applicants renders their relationship of co-habitation, despite its long duration, fundamentally different to that of a married or civil partnership couple'.
The Burdens are not entitled to any further appeal.
In a written statement, they said: 'It is not an exaggeration that we feel as if we have been personally persecuted.
'We are, of course, bitterly disappointed at the result. This is a day we hoped that we, as British citizens, would never see.'
