IHTM25141 | Relevant Business Property: Investigating Relevant Business Property

Where there is a transfer of value business relief is due on the value of ‘relevant business property’, IHTA84/S104 (1). When you investigate the detailed provisions for business relief, you should start by considering if the property transferred comes within one of the categories of ’relevant business property’ in IHTA84/S105 (1).

For deaths and transfers on or after 6 April 1996, and on or before 5 April 2026, there are six categories of property which are capable of qualifying as relevant business property. They are:

• property consisting of a business or interest in a business (IHTM25151). 100% relief

• control holdings of unquoted securities (IHTM25171) in a company. 100% relief

• unquoted shares in a company (IHTM25191). 100% relief

• control holdings of quoted shares (IHTM25201) in a company. 50% relief

• land, buildings, machinery or plant (IHTM25221) used by a company controlled by the transferor or by a partnership of which the transferor was a member. 50% relief

• settled land, buildings, machinery or plant (IHTM25241) in which the transferor had an interest in possession and used in his business (This applies to lifetime transfers only). 50% relief

For deaths and transfers on or after 6 April 2026, the relevant business property categories that previously qualified for unlimited relief at 100% will now only qualify for relief at 100% up to the value of the transferor’s 100% relief allowance (for individuals this is £2.5m or up to £5m if the transferor inherited 100% of their deceased spouse or civil partner’s allowance). The value of any chargeable transfer over and above this allowance will then only qualify for relief at the 50% rate. More details can be found in the chapter beginning at IHTM25500.

The other change taking effect from 6 April 2026 is that unquoted shares or securities that are either:

• traded on a recognised stock exchange (e.g. AIM), or

• traded on a foreign stock exchange, which is not a recognised stock exchange

will now always qualify only for relief at 50%, even if unused 100% relief allowance is available.

In the case of unquoted shares traded on a recognised stock exchange (e.g. AIM) there are also transitional rules limiting the relief to 50% for some lifetime transfers made on or after 30 October 2024. See IHTM25570 for more details.