Hotel Business Property Relief eligibility

[Questions Questions]

I own a 17% indirect interest in a top 5* Thailand full service hotel via a holding company structure with a number of unrelated individuals. The intermediate holdcos do nothing else but hold the investments and account for the dividends on a flow through basis. My question is do my shares qualify for UK IHT BPR relief? Thank you very much for your help.

[AGoodman]

It's impossible to say without knowing more about the holding structure.

Your 17% interest would have to be in topco, which then held controlling interests (e.g. >50%) all the way down the chain to the vehicle that ran the business.

There are a few ways it could potentially fail:

- if one of the companies didn't have greater than 50% interest in its subsidiaries.
- if you had an interest in the hotel but not the hotel business
- if the two were insufficiently connected
- if one of the holding vehicles was not a company (e.g. an LP or LLP equivalent).

This is complicated. You need to get it checked by a professional with BPR expertise.