The following Private Client Q&A provides comprehensive and up to date legal information covering:
It has been assumed for the purposes of this response that:
‘Deceased gifted in her lifetime shares which attract BPR’ means that the deceased made (rather than received) a gift of shares for which business property relief (BPR) was available. It is assumed this gift was a potentially exempt transfer (PET), and
the question concerns the inheritance tax (IHT) treatment of the gift made by the deceased original donor of the shares
The provisions relating to the clawback of BPR contained in section 113A of the Inheritance Tax Act 1984 (IHTA 1984) may apply to adjust the IHT payable
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