Hard2 marksMultiple Choice
Inheritance taxSection BIHT

ACCA · Question 22 · Inheritance tax

Section B - Case 2: Bramble Farms

Arthur owns Bramble Farms, a working agricultural estate. He decides to gift the entire estate to his daughter, Beatrice, during his lifetime. The estate includes agricultural land, a farmhouse occupied by Arthur, and various farm machinery.

The agricultural land has an agricultural value of £800,000 and a market value (due to development potential) of £1,200,000. Assuming Arthur has owned and farmed the land for 10 years, how is relief applied to the £1,200,000 value for IHT?

Answer options:

A.

APR applies to the full £1,200,000.

B.

APR applies to £800,000, and the remaining £400,000 is fully chargeable.

C.

APR applies to £800,000, and Business Property Relief (BPR) applies to the remaining £400,000.

D.

BPR applies to the full £1,200,000, superseding APR.

How to approach this question

Understand the interaction between APR and BPR. APR is applied first to the agricultural value. BPR can cover any excess market value if the asset is used in a business.

Full Answer

C.APR applies to £800,000, and Business Property Relief (BPR) applies to the remaining £400,000.✓ Correct
Agricultural Property Relief (APR) is restricted to the agricultural value of the land (£800,000). However, because Arthur is farming the land commercially, it is a business asset. Therefore, Business Property Relief (BPR) can be applied to the excess market value (£400,000) that arises from the development potential. APR must legally be applied before BPR.

Common mistakes

Applying APR to the full market value, or forgetting that BPR can cover the excess.

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