Where the intention is to keep an FHL property within the family, there are a number of tax planning opportunities. FHL properties that meet the qualifying criteria are able to benefit from s. 165 business asset holdover relief, and they may also qualify for business property relief, so enabling a gift into trust without a lifetime inheritance tax charge. In the latter case, holdover relief under TCGA 1992, s. 260 would apply as it takes priority over s. 165.

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