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Contents

Legislation
Inheritance Tax Act 1984

CHAPTER I BUSINESS PROPERTY

  • Section 103 (1) In this Chapter references to a transfer of value...
  • Section 104 The relief.
  • Section 105 Relevant business property.
  • Section 106 Minimum period of ownership.
  • Section 107 Replacements.
  • Section 108 Successions.
  • Section 109 Successive transfers.
  • Section 109A Additional requirement in case of minority shareholdings.
  • Section 110 Value of business.
  • Section 111 Value of certain shares and securities.
  • Section 112 Exclusion of value of excepted assets.
  • Section 113 Contracts for sale.
  • Section 113A Transfers within seven years before death of transferor.
  • Section 113B Application of section 113A to replacement property.
  • Section 114 Avoidance of double relief.
  1. Chapter I · BUSINESS PROPERTY
  2. The relief.

Section 104 | The relief.

From legislation.gov.uk

(1)Where the whole or part of the value transferred by a transfer of value is attributable to the value of any relevant business property, the whole or that part of the value transferred shall be treated as reduced by 50%. —F1F2

(a)RepealedF2

(b)RepealedF2

...

(1A)But so much of the value transferred as—F3

(a)is attributable to the value of relevant business property that falls within section 105(1)(a), (b) or (bb),F3

(b)constitutes a chargeable transfer that is not an occasion on which tax is chargeable under Chapter 3 of Part 3 (charges on certain settlements etc), andF3

(c)does not exceed the amount of the 100% relief allowance available in relation to that chargeable transfer (see section 124D),F3

is to be treated (instead) as reduced by 100%.

(1B)And so much of the value transferred as—F3

(a)is attributable to the value of relevant business property that falls within section 105(1)(a), (b) or (bb),F3

(b)constitutes a chargeable transfer that is an occasion on which tax is chargeable under Chapter 3 of Part 3, andF3

(c)does not exceed the amount of the 100% trust relief allowance available in relation to that occasion (see sections 124G to 124K),F3

is to be treated (instead) as reduced by 100%.

(1C)Subsections (1) to (1B) are subject to the following provisions of this Chapter.F3

(2)For the purposes of this section, the value transferred by a transfer of value shall be calculated as a value on which no tax is chargeable.

Notes

  1. F1

    Words in s. 104(1) inserted (with effect in accordance with Sch. 12 para. 17 of the amending Act) by Finance Act 2026 (c. 11), Sch. 12 paras. 2(2)(a), 17

  2. F2

    S. 104(1)(a)(b) and words omitted (with effect in accordance with Sch. 12 para. 17 of the amending Act) by virtue of Finance Act 2026 (c. 11), Sch. 12 paras. 2(2)(b), 17

  3. F3

    S. 104(1A)-(1C) inserted (with effect in accordance with Sch. 12 para. 17 of the amending Act) by Finance Act 2026 (c. 11), Sch. 12 paras. 2(3), 17

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