The appellant ran a business of letting five units of self-contained, self-catering holiday accommodation in a property. She transferred 85% of the business to a settlement in two tranches, and claimed business property relief (BPR) (IHTA 1984, Pt V, Ch 1) on both transfers.
HM Revenue and Customs (HMRC) accepted that the appellant was carrying on a business, but decided that the transfers did not qualify for BPR because the business consisted ‘mainly’ of ‘making or holding investments’ (within IHTA 1984, s 105(3)). The appellant appealed.
The business was marketed via a website, correspondence and telephone. The price paid by guests for the accommodation included the use of linen and towels, electricity, kitchen equipment and other household furniture and wifi. A ‘welcome pack’ was provided. The units were cleaned between guests, and a caretaker was available for emergencies. The guests
