.png)
.png)
Holding shares in a trading company by way of a partnership is not a bar to business property relief
KEY POINTS
- Unquoted shares in trading companies are relevant business property.
- Limited liability partnerships are treated as other partnerships.
- HMRC consider that relief is not available where unquoted shares are not held directly.
- The impact of the case of RCC v Nelson Dance.
- Over-reliance on the concepts of “transparent” and “obscure” does not help.
It is often the case that shares in a trading company are held through an investment partnership as indicated by Partnership Holdings (below; click image to enlarge).
Typically this is a limited liability partnership (LLP) but the type of partnership does not usually matter because IHTA 1984 s 267A (below; click image to enlarge) directs that an LLP is to be treated...
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.
