A furnished holiday lettings business was mainly one of making or holding investments, and so was not relevant business property for business property relief purposes.  

Summary 

A furnished holiday lettings business was mainly one of making or holding investments, and so was not relevant business property for inheritance tax (IHT) business property relief (BPR) purposes. 

Background 

The deceased (SC) owned four flats in Crail, Fife. The flats followed the redevelopment and subdivision of a manor house. The manor house had been re-developed and subdivided into five flats. Over the years, four of the five flats came to be owned by SC between 1971 and 1996, with Flats 2, 3, and 4 being used for holiday lets. 

SC started a holiday lettings business in 1989, which continued to be