Deceased held 1,000 ordinary shares (25%) in a farming business (limited company), valued at £210,000 (including a discount of 30% as a non-controlling interest). The valuation has been done on a net asset basis and comprises agricultural land (discounted value £51,000); previous farm buildings let on a commercial basis (discounted value £92,000); and other business assets related to the farming activities (discounted value £67,000). Given APR should be claimed before BPR:
1 should the business interest simply be included as £210,000 and 100% BPR claimed; or
2 should the discounted value be apportioned as set out above, with APR claimed re: the land; and BPR claimed re: the remainder explaining the company’s primary activity is farming and letting of the commercial units is subsidiary to the main farming activity?