Charnley v HMRC [2020] WTLR 93

Wills & Trusts Law Reports | Spring 2020 #178

Mr Gill’s estate included the house in which he lived, a brick barn and outbuildings and 21 acres of permanent pasture. During the relevant period Mr Gill did not own any livestock. He allowed farmers to graze their livestock on his agricultural land under annual grazing licences. It was not disputed that the house was of a character appropriate to the farm.

HMRC refused agricultural property relief (‘APR’) in respect of the value of the house, barn and outbuildings on the basis that neither the house nor outbuildings were occupied for the purposes of agriculture, and refused the ...

APR and BPR: Attention to detail

Christopher McNall analyses a recent First-tier Tribunal judgment that demonstrates the importance of thorough evidence in cases where the bases for reliefs are tested ‘The key issue, upon which the tribunal focused, was whether there existed “a functional connectivity” between Mr Gill’s occupation of the house and the agricultural activities that took place on the …
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