³ÉÈËÓ°Òô

Article summary

Private Client analysis: This forms another in a list of cases where HMRC have successfully challenged a claim for BPR in property based businesses. The deceased was running a wild fisheries business from 27 acres of land including a river and tributaries. The claim also covered 2/7 of her home, on the basis this was used to run the business and host customers. She ran the business for 17 years following her husband's death, and worked long days to maintain the river and banks and manage the bookings and activities. However, the court held that the nature of the non-investment services did not prevent the usual characterisation of the business, being one whose income was derived from property, as being that of an investment business. Significant additional services, such as catering, tuition, or equipment hire are noted as hypothetical points that may have changed the outcome. Written by Robert Davies, managing associate at Foot Anstey...