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HMRC internal manual

Inheritance Tax Manual

Relevant Business Property: Investigating Relevant Business Property

Where there is a transfer of value business relief is due on the value of ‘relevant business property’, IHTA84/S104 (1). When you investigate the detailed provisions for business relief, you should start by considering if the property transferred comes within one of the categories of ’relevant business property’ in IHTA84/S105 (1).

For deaths and transfers on or after 6 April 1996, there are seven categories of property which are capable of qualifying as relevant business property. They are:

  • property consisting of a business or interest in a business (IHTM25151).   100% relief
  • control holdings of unquoted securities (IHTM25171) in a company.   100% relief
  • unquoted shares in a company (IHTM25191).  100% relief
  • control holdings of quoted shares (IHTM25201) in a company.   50% relief
  • land, buildings, machinery or plant (IHTM25221) used by a company controlled by the transferor or by a partnership of which the transferor was a member.   50% relief
  • settled land, buildings, machinery or plant (IHTM25241) in which the transferor had an interest in possession and used in his business (This applies to lifetime transfers only).   50% relief