In the case of Executors of Joyce Graham (deceased) vs. HMRC, the First-tier tax tribunal (FTT) has ruled that a holiday letting business qualified for business property relief (BPR) for inheritance tax purposes.
In recent years HMRC have successfully challenged a number of BPR claims made for holiday let businesses on the basis that the businesses consisted wholly or mainly of making or holding investments.
In this case guests were provided with ‘exceptional level of service and amenities’ which the FTT decided were sufficiently extensive to mean that the business was not one of property investment.
David Nash, Partner said “This case confirms that where the type, quality and extent of services provided over and above the mere provision of accommodation is significant, a BPR claim can be successful. The bar remains high however and owners of holiday let businesses should continually review matters and seek advice if they wish to secure BPR”.