THE EXECUTORS OF KEITH DENIS LEWIS BERESFORD (DECEASED) v HMRC [2026] UKUT 00285 (TCC)
Summary
The Upper Tribunal Tax and Chancery considered an inheritance tax appeal concerning business property relief for shares in a company. The central issue was whether the company’s business consisted wholly or mainly of making or holding investments under section 105(3) of the Inheritance Tax Act 1984.
Why it matters
This is relevant to surveyors involved in valuation and estate-related work where company shareholdings and business assets may be assessed for tax purposes. The decision may also be of interest where property-holding companies are being reviewed for inheritance tax relief eligibility.
Key points
- Upper Tribunal Tax and Chancery decision dated 29 July 2026
- Appeal concerned inheritance tax and business property relief
- Issue turned on section 105(3) IHTA 1984
- Tribunal examined whether the company was mainly an investment business
- Potential relevance to property-holding company structures
Organisations:
HMRC, Upper Tribunal Tax and Chancery
Regulations:
Inheritance Tax Act 1984, section 105(3) IHTA 1984, business property relief
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