BPR & the ‘Wholly or Mainly’ Test - The Current Position

Introduction

Business Property Relief (‘BPR’) can provide valuable inheritance tax relief, but only where the business satisfies the relevant statutory conditions. The ‘wholly or mainly’ test is often where the real difficulty lies. If a business falls on the wrong side of the line, BPR may be denied altogether, with significant consequences for your client.

This practical short webinar begins with the essential principles of BPR, explaining what the relief applies to, when it is available and how the relevant conditions operate. It then focuses on the ‘wholly or mainly’ requirement, including the interpretation of ‘mainly’ and the significance of the 50% threshold.

Recent case law will be examined to show how the courts are currently approaching this requirement, highlighting the factors that can determine whether a business qualifies and where the boundaries of the relief lie.

The webinar will also use worked examples and practical scenarios to bring the rules to life, helping you assess whether a client’s business is likely to qualify for BPR and identify the key issues that need to be investigated when advising.

What You Will Learn

The webinar will cover the following:

• The fundamentals of Business Property Relief (‘BPR’), including what it applies to and the key conditions for qualification
• Recent case law and what the latest decisions mean for practitioners
• The potential consequences of getting the BPR analysis wrong
• Practical examples illustrating what does and does not satisfy the business definition
• Practical tips for assessing BPR eligibility and advising clients when these issues arise
• A clear, practical understanding of the current position and how to apply it when advising clients