Commentary

I12.504 Combined gifts

IHT, trusts and estates

I12.504 Combined gifts

I12.504 Combined gifts

The comments which follow are only relevant in circumstances where 100% business property relief is not available.

In the context of an individual who is considering making a combination of exempt gifts (eg to charity) and non-exempt gifts, there can be an advantage in the transferor making a combined exempt and non-exempt gift of the same property rather than effecting two separate transfers on consecutive days.

Example

A owns 80,000 (80%) shares of AB Ltd. A's brother B owns the remaining 20,000 (20%).

Specimen share values:80% (full winding up control):£100

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