Land or buildings and machinery or plant qualify for relief at 50 per cent if, immediately before the transfer, they were:

(1)settled property in which the transferor was beneficially entitled to an interest in possession; and

(2)used wholly or mainly for the purposes of a business carried on by the transferor (IHTA 1984, s. 105(1)(e)).

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

This provision is, however, partly redundant in view of Fetherstonhaugh & Ors v IR Commrs [1984] BTC 8,046, discussed below.

Example 1

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