Claims for business property relief on let property have always been resisted by HMRC. Statements made by the Chief Secretary to the Treasury, during the passage of the Finance Bill in 1976 that introduced the current business property relief legislation, made it clear that it was not intended to extend to landlords. However, the point has been heavily litigated because of the lack of clarity in the legislation. The most relevant cases on the issue of business property relief and property-based businesses are considered here.

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