Readers’ forum: Caravanned

Our client runs a small caravan site and the issue of inheritance tax business property relief has arisen. The site is small and can accommodate only 60 average-sized caravans. At present 51 caravans are sited there permanently for which the owners pay a small additional fee of £50 a year. The site also includes a toilet shower block and waste disposal facilities. The client’s home adjoins the site and his kitchen is regularly in use for visits from the caravan owners many of whom are now good friends. Our client also maintains the site mowing it and keeping it in good order.

We do not think that the caravan site will qualify for business property relief on the basis of decided cases such as Hall & Hall (Hall’s Executors) v CIR [1997] SSCD 126 and Powell & Halfhide (Pearce’s Personal Representatives) v CIR [1997] SSCD 181. We have also mentioned George &...