ACCA · Question 22 · Inheritance Tax
Section B: Case 2 - Eleanor Vance
Scenario: Eleanor Vance, a wealthy agricultural landowner, made several lifetime transfers before her death on 12 November 2023. On 15 August 2021, she transferred £450,000 of cash into a discretionary trust. Eleanor paid the lifetime Inheritance Tax (IHT) arising on this transfer. She had made no previous lifetime gifts.
Question: At her death, Eleanor owned a farmhouse and surrounding farmland. She had lived in the farmhouse and actively farmed the land herself for 18 months prior to her death. Before that, she had rented the land and farmhouse to a tenant farmer for 6 years.
Does the agricultural property qualify for Agricultural Property Relief (APR) on her death?
Answer options:
No, because she did not occupy it for agricultural purposes for at least 2 years prior to death.
Yes, because it was owned by her and occupied by someone for agricultural purposes for at least 7 years.
No, because the farmhouse cannot qualify for APR under any circumstances.
Yes, because all agricultural land automatically qualifies for 100% APR regardless of ownership length.
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