[Correspondence between Institute of Taxation and Revenue, 11 May 1994]

The Institute of Taxation wrote to the Revenue in the following terms on 16 December 1993:

“One of our members has pointed out that there seems to be some uncertainty as to whether the existence of an accruer arrangement in a partnership agreement infringes, in relation to transfers made on death, the requirement in IHTA 1984, s. 113 that if property is to be relevant business property for purposes of business relief that property must not be subject to a binding contract for sale. There is, of course, a similar requirement in relation to agricultural relief.

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