I understand that the Deputy is referring to the issue of an extension of the provision of business property relief in the context of capital acquisitions tax to caravan park operators. The business relief provisions were introduced to alleviate the threat to active trading businesses and the potential threat to employment in those businesses from having to fund heavy CAT liabilities from current resources. A business consisting of the operation of a caravan park, which is passed on by way of a gift or an inheritance, is not excluded from the business relief provisions. A difficulty may, however, exist for certain caravan park operations where the business activity is predominantly one of exploiting an interest in land.
I understand that Revenue has published its practice statement on the circumstances in which caravan parks qualify for the relief. The approach of the Revenue Commissioners is to look at the type of letting activity which takes place at the caravan site that is, how much of the letting relates to the provision of furnished caravans owned by the business and how much involves the letting of pitch sites. As a general guideline, where an operator's own caravans account for at least half of the total number of lettings, the caravan park is likely to qualify for business relief. Instances where the letting of pitch sites predominates will not qualify for the relief as the business primarily involves an exploitation of an interest in land.