Commentary

I1.302 CTT—1975 to 1978

IHT, trusts and estates

I1.302 CTT—1975 to 1978

I1.302 CTT—1975 to 1978

The tax as first introduced was intended to provide an integrated gift and death tax. It rested on the principle of lifetime cumulation so that the tax chargeable on a transfer of value was related to the total value of all previous chargeable transfers made by the transferor since 26 March 1974. Death was regarded as the occasion of the final transfer and the value of the property transferred on death was cumulated with those of all the transfers that the deceased had made in his lifetime. The integration was to be enhanced by having the same rates apply to all gifts of property, whether made inter vivos or on death. FA 1975 also introduced a comprehensive taxing code for settled property. Special rates applied to settled property and to transfers involving close

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