| Commentary

36.3 Inheritance tax

| Commentary

36.3 Inheritance tax

As with the lifetime gift of a sole trade or a share in a partnership business1, a lifetime gift of shares in a limited liability company will normally be a transfer of value2 for inheritance tax purposes but will usually be a potentially exempt transfer3 and therefore only chargeable if the transferring shareholder dies within seven years of the transfer4. As a result, where a shareholder gives away his shares in the company and survives for at least seven years, there will be no inheritance tax consequences, but if he dies within that period then the transferee

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