The taxpayer was a member of Lloyds. He had to obtain a guarantee of his liabilities from his bank, who in turn took a charge over a freehold reversion which he owned. It was claimed that having been given in charge for business purposes, the taxpayer could take advantage of business property relief for Inheritance tax purposes. This was not correct. The use of the asset to support a guarantee did not of itself make the asset one used for business purposes.
References: Times 30-Mar-2001
Statutes: Inheritance Tax Act 1984 105(1) (a)
Last Update: 21 November 2020; Ref: scu.82351