Firth & anr v Commissioners for HMRC [2022] WTLR 1297
Wills & Trusts Law Reports | Winter 2022 #189The appeal was brought by Mr and Mrs Firth in their capacity as trustees of the L. Batley 1984 Settlement (the trust) against notices of determination issued to the trustees by HMRC on 7 September 2018, which refused Inheritance Tax (IHT) Business Property Relief (BPR) on the grounds that the interest of the trustees in the business carried on by the Lawrance (Hotel Living) Ltd (The Lawrance) consisted mainly in the holding of investments and was therefore not a qualifying business for the purposes of BPR.
On 14 November 1984 Lawrance Batley established the trust. Prior to 2012 th...