Land or buildings and machinery or plant owned by the transferor qualify for relief at 50 per cent if, immediately before the transfer, they were used wholly or mainly for the purposes of a business carried on by:

(1)a company controlled by the transferor; or

(2)a partnership of which the transferor was then a partner (IHTA 1984, s. 105(1)(d)).

In respect of transfers before 10 March 1992 the rate was 30 per cent.

Example 1

Henry is the senior partner in a firm of accountants who carry on business in office premises owned by Henry. Henry dies and leaves both the building and his interest in the firm to his son James, one of the junior partners.

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