BPR

Question 1

what is BPR?

Answer 1

BPR is a way of reducing the IHT liability on a lifetime transfer or in someone’s death estate, on a specific
asset, by 50% or 100%, depending on certain conditions

Question 2

what qualified for 100% relief?

Answer 2

transfer by an unincorporated business
the whole of a sole trade business
a share in a partnership
these need to be trading businesses so can’t be investment businesses

• unquoted shares or securities
• need to be held in trading company.

the business, shares or security need to be held for a minimum of 2 years prior to the transfer to the donor.
- BP replaces with other BP still meets the 2 year rule.

Question 3

what qualifies for 50% relief?

Answer 3

certain land, buildings, plant or machinery being used in a business
- relief only available if they are used in a trading company which the donor has control over or by a
trading partnership in which the donor is a partner
- so note that it will never apply to such assets used in a sole trader business

• quoted shares or securities being transferred
  donor must have voting control of the trading company immediately before the transfer

Question 4

what are the rules for BPR for investment businesses?

Answer 4

= investment business doesn’t qualify
- shares in a trading company that invests we will deduct the excepted assets

transfer of value* total assets less expected assets/total assets