Inheritance Tax Act 1984 section 32A

Associated properties

Section 32A deals with the inheritance tax treatment of "associated properties" — historic buildings together with their surrounding land and contents — when they have benefited from conditional exemption, and sets out when chargeable events arise affecting the entire group of associated properties.

  • Associated properties comprise a designated historic building together with any related land essential to its character and any historically associated objects — these are treated as a single linked group for conditional exemption purposes.
  • A breach of undertaking regarding any one of the associated properties, or the death or disposal of any one of them, can trigger a chargeable event across the entire group of associated properties that have received conditional exemption.
  • A chargeable event is avoided where the property passes to a national body (such as a museum or the National Trust), is accepted in lieu of tax, or qualifies for a fresh conditionally exempt transfer — and where only part of the group is disposed of, undertakings must be given for the retained properties to prevent a charge on the whole group.
  • The Treasury has discretion to limit the chargeable event to just the specific property affected, rather than the whole group, where a breach of undertaking or disposal has not materially affected the overall entity of associated properties.

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