Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Structure strictures

30 September 2008 / Jan Ellis
Issue: 4178 / Categories: Comment & Analysis , Business , Capital Gains , Inheritance Tax

Will shares in group companies be eligible for business property relief?

KEY POINTS

  • The basic business property relief rules.
  • The rules and case law.
  • A checklist.
  • Groups and 'deep' groups.
  • Split shareholdings.

Since the abolition of taper relief in April 2008 we have lost the historic tension that could sometimes arise regarding whether to structure groups of companies in a way that would qualify for capital gains tax taper relief or for inheritance tax business property relief (BPR).

While the taper relief rules are still relevant to establish eligibility for substantial shareholdings relief many companies are now giving BPR structuring more attention. As are HMRC which announced on 1 May 2008 that for an initial six-month period they would give non-statutory clearances in relation to BPR.

The first part of this article looks at the main conditions...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

back to top icon