Inheritance Tax Act 1984 section 106

Minimum period of ownership

Section 106 establishes the minimum period for which business property must have been owned before it can qualify for business property relief on a transfer of value.

• Property must have been owned by the transferor for a continuous period of at least two years immediately before the transfer of value.
• If the two-year ownership condition is not met, the property cannot be treated as relevant business property.
• Without qualifying as relevant business property, no business property relief is available to reduce the value transferred.
• The ownership must be unbroken throughout the entire two-year period — there is no provision for aggregating separate periods of ownership.