IHTA84/S105 (1)(e) applies to
Under IHTA84/S105 (6) the land, etc, does not qualify for relief
under IHTA84/S105 (1)(e) unless the business carried on by the
transferor is relevant business property (
IHTM25151) in relation to the transfer.
IHTA84/S105 (1)(e) refers only to the moment of time immediately before the transfer. There is nothing in Chapter I of Part V to require the transferor to have used the land, etc, throughout any earlier period (contrast the minimum period of user ( IHTM25223) requirement in IHTA84/S112 (3) referred to in which applies to IHTA84/S105 (1)(d) but not to IHTA84/S105 (1)(e)). However the normal minimum period of ownership rules apply. This section applies to lifetime transfers only.
You should also check the rules for the definition of business ( IHTM25153) and machinery or plant ( IHTM25227).