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HMRC internal manual

Inheritance Tax Manual

Example NODs: SAV NOD

Inheritance Tax

Notice of Determination

Under Section 221, Inheritance Tax Act 1984

TO: Mr Andrew Bernard Carr date 13 February 2003

c/o Arnold and Sons

27 Liver Place ref F123123/01A



The Commissioners of Her Majesty’s Revenue and Customs have determined -

In relation to

a) the Settlement made on 1 January 1999 by Mr Alan Bertram Carr as settlor and Mrs Carol Diane Carr, Andrew Bernard Carr and Graham Harold Castle as trustees;

b) the transfer on 1 January 1999 by Alan Bertram Carr of 500 £1 ordinary shares in Carr’s Caravan Site Ltd (“the Shares”).

That, having regard to the provisions of section 105(3) Inheritance Tax Act 1984, the Shares are not relevant business property for the purposes of section 104 of that Act as the business of the Company consists wholly or mainly of making or holding investments.

(Name of issuing officer)

For the Commissioners of Her Majesty’s Revenue and Customs

Right of appeal

If you wish to appeal against this determination (or any part of it), you should within 30 days after service of this notice give notice of appeal in writing, specifying the grounds of appeal, to The Appeals Team, HMRC Inheritance Tax, Trusts & Estates, Ferrers House, PO Box 38, Castle Meadow Road, Nottingham, NG2 1BB

If you do not appeal the determination will be conclusive in accordance with Section 221(5) of the Inheritance Tax Act 1984.