Commentary

I1.505 Restrictions on 'transfer of value'

IHT, trusts and estates

I1.505 Restrictions on 'transfer of value'

I1.505 Restrictions on 'transfer of value'

Having extended the definition of transfer of value to cover practically any deliberate act or omission that reduces the value of a person's estate, the legislation then introduces qualifications to the term, as follows:

  1.  

    (a)     The main exception is that which is referred to in this work as the commercial transactions exemption1. Where there is a transaction not intended to confer gratuitous benefit, not forming part of some larger series of transactions intended to confer gratuitous benefit, and made at arm's length between persons not 'connected' with each other, it is not a transfer

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