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Livery case on business property relief

12 September 2017 / Rachel Smith , Jonathan Hayes
Issue: 4615 / Categories: Comment & Analysis

O happy horse


  • Four categories of livery businesses.
  • Business property relief does not apply if a business consists mainly of land or making investments.
  • The taxpayer’s business offered more than the right to occupy land.
  • Decision contrasts with others which held that services were ancillary to the letting of land.

HMRC denied business property relief (BPR) on the late Mrs Vigne’s livery business on the basis that there were insufficient activities or expenses of a business nature. The officer characterised it as a business mainly of holding investments even while accepting that the operation of a livery business necessitates the provision of services as well as land. However the First-tier Tribunal (TC6068) held that the relief was due.

The Inheritance Tax Act 1984 provides that full relief is available on ‘relevant business property’ defined...

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