In TAXguide 15/17, the Tax Faculty has published correspondence between Emma Chamberlain and HMRC relating to the availability of business property relief (BPR) in complex group structures. It extends the guidance offered by TAXguide 05/11 on inheritance tax and BPR.
TAXguide 15/17 is an update to TAXguide 5/11 in which the Tax Faculty provides guidance on the practical application of the business property relief (BPR) rules in Chapter I, Part V, Inheritance Tax Act 1984 as they apply to groups of companies.
Since that publication correspondence has been exchanged between Emma Chamberlain and HMRC exploring the availability of BPR in a more complex group structure.
We are extremely grateful to Emma for allowing us to publish the correspondence. HMRC have agreed to the publication of their response.
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