Qualification by occupation for two years

In respect of transfers of shares or securities in farming companies, IHTA 1984, s. 117 is replaced by s. 123(1), which provides that relief is given where:

(1)the company has occupied the property for agricultural purposes throughout the period of two years ending with the date of the transfer (s. 123(1)(a)(i)); and

(2)the shares or securities were owned by the transferor throughout that period (s. 123(1)(b)(i)).

Occupation by a company is presumably established by occupation by its directors and employees. The Act does not specify that the transferor must be one of the persons who is in actual occupation of the property.

Example 1

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