IHT Business Property Relief Expert Witness UK

Inheritance Tax Business Property Relief (BPR) disputes require expert evidence when HMRC's Shares & Assets Valuation (SAV) team challenges whether a business qualifies as a trading (not investment) business, when the value of BPR-eligible business interests is disputed, or when the excepted assets rule is applied to reduce the relief available.

The trading vs investment test under IHTA 1984 s105 requires analysis of whether the business is wholly or mainly not of an investment nature. The tax expert analyses the proportion of investment vs trading activities through both balance sheet analysis and activities analysis to determine BPR qualification.

IHT valuation disputes also require expert evidence on the correct valuation methodology for unquoted business interests, addressing whether HMRC SAV's adopted value is defensible and producing independent counter-valuations where appropriate.