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BPR ― application to groups of companies

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance

BPR ― application to groups of companies

Produced by a Tolley Trusts and Inheritance Tax expert
Trusts and Inheritance Tax
Guidance
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This guidance note explains how BPR applies to holding companies and to groups of companies. Without special provision, a holding company would not qualify for BPR as it is not in its own right a trading company and this guidance note covers how and when a holding company will qualify. It also considers the approach to be taken to a group scenario when assessing the BPR status of a shareholding. This covers the assessment of the trading status of the group first and then of each individual subsidiary. If a subsidiary is not a trading company in its own right then its value is disregarded. It consolidates and links to the guidance in this area, much of which is included in various correspondence between HMRC and the professional bodies.

Basic principles

Unquoted shares, quoted shares or securities from a controlling holding or unquoted securities from a controlling holding fall into the categories of property which can qualify for BPR. See the BPR ― relevant business property guidance note for further information.

However,

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