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Line in the sand

12 November 2013 / Ian Maston , Priya Dutta
Issue: 4428 / Categories: Comment & Analysis , Inheritance Tax

What is the limit when deciding if a provider of land is eligible for business property relief?


  • Leave to appeal against denial of business property relief is refused in Pawson.
  • But what other land-based businesses are likely to be refused relief?
  • The “spectrum” of business types and the decision of the “intelligent businessman”.
  • In Pawson the services provided were “no way near” sufficient for relief to be given.
  • Is it clear where parliament intended the dividing line to be drawn?

On 2 October 2013 Briggs LJ refused the taxpayer’s leave to appeal to the Court of Appeal in the case of HMRC v Pawson [2013] (UKUT 050 (TCC)). The case concerned a claim for inheritance tax business property relief in relation to a furnished holiday let (FHL).

To recap the First-tier Tribunal had allowed the taxpayer’s claim to relief but the decision...

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