Application of BPR and APR to non-UK property

Produced by a Tolley Trusts and Inheritance Tax expert

Trusts and Inheritance Tax

Guidance

This guidance note discusses the application of BPR and APR to property which is not situated in the UK.

BPR ― application to non-UK property

For an overview of BPR, see the BPR overview guidance note which signposts to other detailed notes on various aspects of BPR.

BPR has no territorial limitation and BPR will apply to non-UK assets in the same way as UK assets.

The only territorial oddity is that a business which is wholly that of a market maker and which is carried on in the UK or EEA is not treated as an investment business.

When considering whether a share or security is quoted or unquoted, ‘quoted’ means listed on a recognised stock exchange.

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