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Introduction to heritage property

The preservation and public enjoyment of national heritage property has been supported by tax policies of governments since Finance Act 1896. In return for opening up his heritage property to the public (and preserving it), the owner may receive favourable IHT and CGT treatment with respect to that heritage property. Principally, these benefits take the form of conditional exemption from inheritance tax under IHTA 1984, ss 30–35A (with associated relief from CGT under TCGA 1992, s 258, see below).

Practical guidance in relation to the capital taxation of heritage property can be found in HMRC’s booklet Capital taxation and the national heritage to which references are made throughout this note.

Conditional exemption is only a deferral of tax and therefore is not as advantageous as some other reliefs such as business property relief on a stately home which opens to the public as a business. Conditional exemption is also less popular now than it used to be for two reasons. Firstly, since 1986, there