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Commentary

I7.333A Companies and replacement APR property

IHT, trusts and estates

APR property replaced by owning company

If the property in question replaced other agricultural property within the seven-year period, the period is extended and the company's combined ownership of both properties has to comprise a total of seven years out of the ten immediately preceding the date of transfer1. If the replaced property itself replaced other property, combined occupation of the three properties is counted, and so on. Throughout the qualifying period of seven years the property must have been occupied for agricultural purposes either by the company or another2.

Where one or more replacements have been made during the ten-year period, the relief cannot exceed 'what it would have been had the replacement

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