Trustees lose £1.7m business property relief claim

Two trustees have lost a case in the First Tier Tribunal over a dispute about whether a claim for business property relief was allowable after HMRC ruled it out

Mr and Mrs Bruce and Rita Firth were trustees of the Batley 1984 Settlement and operated Lawrance (Hotel Living) Limited, which ran a number of aparthotels, and they went to court over HMRC’s rejection of a claim for business property relief (BPR).

The trustees appealed against notices of determination issued by HMRC on 7 September 2018 refusing inheritance tax business property relief.

HMRC rejected the claim on the grounds that the interest of the trustees in the business carried on by Lawrance (Hotel Living) Limited consisted mainly in the holding of investments and was not a qualifying business for the purposes of BPR.

Your free features:

Breaking news and expert analysis
Customisable daily newsletters
Six free CPD learning modules each year
Personalised CPD tracker
Top 75 Firms league tables
Regulatory changes
Hardman’s Tax Data

Tax | Property 118 wins case against HMRC over notifiable scheme notices

Finance | Legal updates: defective request to view register of members under section 117

Tax | High Court throws out farm tax case ‘at first hurdle’

Finance | Legal updates: treating accounting liabilities as assets in business sale

Tax | Personal tax changes from 6 April 2026

Navigate

Tax Services

Your free features:

Sign up to Business & Accountancy Daily