Commentary

104 Transfers of value—relief generally

CHARITIES AND CHARITABLE GIVING vol 6(2)
| Commentary

104 Transfers of value—relief generally

| Commentary

B: CAPITAL TAX RELIEFS

1: INHERITANCE TAX RELIEF

104 Transfers of value—relief generally

A transfer of value1 is an exempt transfer2 for the purposes of inheritance tax, if it takes effect in favour of a particular charity or registered club3 or if the property becomes subject to a trust for charitable purposes only4. The exempt status is preserved even if the trust fails ab initio, provided that the property will be saved for charity by a cy-près scheme5.

There are, however, certain restrictions. The transfer is not an exempt transfer if the gift

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