Business Property Relief

Investors have raised the issue of Business Property Relief on Manolete shares in respect of Inheritance Tax.

The Manolete Board therefore sought legal clarification by way of an independent Counsel’s opinion. Manolete’s Chief Finance Officer, Mark Tavener instructed Michael Firth QC of Gray’s Inn Tax Chambers, a foremost legal expert on business property relief matters and Inheritance Tax.
Click here to download a PDF copy of the response.

Manolete sought independent advice in respect of, “the availability of business property relief from UK inheritance tax in relation to the shares in Manolete Partners PLC (MPP). Specifically, the question is whether relief would be denied on the basis of IHTA 1984, s.105(3).”
Click here to download a PDF copy of the letter.

Mr Firth responded on 27 January 2020 making clear in a detailed opinion that, “assuming the other conditions for business property relief are met in individual cases, my view is that the relief is available.”

We hope this is helpful, but we must stress that individuals’ tax affairs are fully their own responsibility. Individuals should take their own tax advice in respect of Business Property Relief before doing or refraining from doing anything which might have tax consequences for them. It should also be noted that HMRC are able to change the various reliefs available for inheritance tax at their discretion.