Medium2 marksMultiple Choice
Inheritance taxSection BIHTBusiness Property Relief

ACCA · Question 22 · Inheritance tax

Section B: Case 2 - Arthur Pendelton's Estate

Scenario: Arthur Pendelton died on 15 February 2024. He owned a working farm, 'Oakwood Farm', which he had actively farmed himself for the last 15 years. The farm consists of agricultural land, a farmhouse where Arthur lived, and two farm cottages occupied rent-free by his farm workers.

Question: Arthur also owned 15% of the unquoted ordinary share capital in 'AgriSupplies Ltd', a trading company that supplies farming equipment. He had owned these shares for 4 years. Do these shares qualify for Business Property Relief (BPR), and if so, at what rate?

Answer options:

A.

No, because he owned less than 50% of the shares.

B.

Yes, at 50%

C.

Yes, at 100%

D.

No, because they are not agricultural property.

How to approach this question

Identify the asset type: unquoted shares in a trading company. Check the ownership period: 4 years (meets the 2-year minimum). Determine the BPR rate: unquoted shares attract 100% BPR, regardless of the size of the shareholding.

Full Answer

C.Yes, at 100%✓ Correct
Business Property Relief (BPR) is available on relevant business property owned for at least two years. Unquoted shares in a trading company qualify for 100% BPR. There is no minimum shareholding requirement (unlike BADR for Capital Gains Tax). Since Arthur owned the shares for 4 years and the company is a trading company, they qualify for 100% BPR.

Common mistakes

Confusing the BPR rules with BADR rules (which require a 5% holding) or assuming 50% BPR applies because he doesn't have control.

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