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Tax updates: July 2015

Our monthly round-up of significant tax cases includes business property relief denied in Green case over Flagstaff Holidays, non-cash consideration forms part of disposal proceeds, appeal allowed in Jackson case over takings claims, country by country reporting rules released and Monsanto considers relocating tax base to UK for tax advantage 

Case report: Business Property Relief denied over Flagstaff Holidays

In the case of Green v Revenue & Customs [2015] UKFTT 236 (TC,) Mrs Green ran a business called Flagstaff Holidays (the business), which lets five units of self-contained holiday accommodation in a property called Flagstaff House(the property).

Green transferred 85% of the business to a settlement called the Mrs ACC Green Settlement (the trust) in two tranches (£583,300 and £1,060,200 respectively) and claimed that both transfers qualified for 100% business property relief (BPR) under the Inheritance Tax Act 1984, Part v, Ch 1 as being ‘relevant business property’.

HMRC accepted that Green was carrying on a business, but decided that the transfers did not qualify for BPR because the business consisted ‘mainly’ of ‘making or holding investments’.

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