The executor of a deceased individual appealed against a determination by HMRC that business property relief (BPR) for inheritance tax (IHT) purposes was not due in respect of the deceased's shares in an unquoted company. HMRC's refusal to allow BPR was on the basis that the business of the company consisted wholly or mainly of holding investments, such that the deceased’s shares did not qualify for relief as relevant business property (under IHTA 1984, s 104).
The company owned a business centre, which provided industrial and warehouse space for small to medium-sized businesses. The site had a reception area, with a receptionist employed by the company. Businesses occupying the business centre paid monthly licence fees. The businesses also paid a service charge which, apart from a receptionist, covered various other services including the cleaning of common areas and site security.
The license agreement also
