Claim to Relief From Inheritance Tax Successful for Holiday Letting Arrangement

Claim to Relief From Inheritance Tax Successful for Holiday Letting Arrangement

Claim to relief from Inheritance Tax successful for holiday letting arrangement

The First Tier Tribunal (FTT) has ruled in favour of a holiday letting business and allowed Business Property Relief (BPR) for IHT purposes, after other important cases which have denied BPR to holiday lets.

Personal representatives of Mrs G’s estate claimed a deduction in the computation of the value of her estate on the basis that the part of her interest in Carnwethers, an old farm house containing four self-contained self- catering flats, was by virtue of the business she ran there, relevant business property within IHTA 1984, s.103 to 114 (and therefore capable of Business Property Relief).

The FTT concluded that this was an exceptional case as certain features provided by the business distinguish it from normal actively managed holiday letting businesses including personal care lavished upon guests and attention to environmental matters providing a unique venue for them.

It was concluded by the FTT that Carnwethers was more like a family run hotel than a second home let out in the holidays.

If you have furnished holiday lettings and you wish to consider your IHT position, please contact one of our tax partners.


Steve Crompton
Partner – Head of Tax
direct dial: 01942 292541
mobile: 07790 840394
email: steve.crompton@jsllp.co.uk

Chris Barrington
Tax Partner
direct dial: 01942 292505
mobile: 07730 436070
email: chris.barrington@jsllp.co.uk
 

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