Inheritance Tax Act 1984 section 104

The relief

Section 104 provides for business property relief, which reduces the value transferred by a transfer of value where that value is attributable to relevant business property.

• Where the value transferred is attributable to relevant business property, the value is reduced by either 100% or 50% depending on the type of property involved.
• A 100% reduction applies to a business or interest in a business, unquoted shares giving control of a company, and any other unquoted shares in a company.
• A 50% reduction applies to all other categories of relevant business property.
• The value transferred is calculated as a value on which no tax is chargeable, meaning the reduction is applied before any grossing-up for tax purposes.