Another furnished holiday cottage business fails to get BPR

The First Tier Tribunal case of the Executors of the estate of the late Gertrud Tanner is another example of a holiday cottage business which has failed to qualify for BPR from Inheritance Tax because none of the additional services were sufficient to take the business over the “non- investment line”.

The taxpayer argued that the leading case of Pawson had become dysfunctional.  But the tribunal's view was that if that was the case, then it was for the higher courts or Parliament to deal with. The non-legal member of the tribunal expressed regret that the case law on this aspect of BPR “has strayed from the apparent purpose of the underlying legislation”. 

As the law currently stands, the decision will come as no surprise to watchers of the long line of similar cases.

Executors for the estate of the late Gertrud Tanner (TC9456)

As the law currently stands the decision will come as no surprise to watchers of the long line of similar cases.

https://assets.caselaw.nationalarchives.gov.uk/ukftt/tc/2025/328/ukftt_tc_2025_328.pdf