Relief is not available in respect of a business or interest in a business, or shares in or securities of a company, if its business consists wholly or mainly of one or more of the following:

dealing in securities, stocks or shares;

dealing in land or buildings;

making or holding investments (IHTA 1984, s. 105(3)).

The property of such businesses is not ‘relevant business property’. Thus, where a business falls foul of IHTA 1984, s. 105(3), its whole value is disqualified, and not just that part attributable to investments.


Philip's business consists mainly of dealing in land, but also includes the management of commercial woodlands.

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