The nature of a company’s business of providing serviced offices was such that its business consisted wholly or mainly of making or holding investments, such that no business property relief was due for inheritance tax purposes. 

Summary 

The nature of a company’s business of managing serviced offices was such that its business consisted wholly or mainly of making or holding investments, such that no business property relief (BPR) was due for inheritance tax (IHT) purposes. 

Background 

The deceased (DLB) died on 18 September 2018. The appellant executors claimed BPR on the basis that DLB’s shares in a company (F) were relevant business property. The appellants claimed that F’s business consisted wholly or mainly of being the holding company of another company (N) whose business did not fall within IHTA 1984, s 105(3).  

F owned the