I3.112 Loss to the estate
The notion of causing loss to the estate of the person making the disposition is central to the concept of a transfer of value. It defines not only what is a transfer of value but also its extent and, by inference, its timing (see I3.131). 'Estate' here is the aggregate of all property to which a person is beneficially entitled1, but excluded property (see I3.217) leaving the estate as a result of a disposition is left out of account in assessing whether and how far it is a transfer of value2, and settled property in which a person has a qualifying interest in possession (QIIP) is expressly part of his estate (see I5.102).
A disposition which causes no loss, such as a sale for full value in cash or the settlement of property or trusts which gives the settlor a QIIP in all the property settled, cannot be a transfer of value.
A disposition which causes loss may still be excluded from being a transfer of value by one or more of the statutory provisions considered in I3.141–I3.160. For example, Bob sells a old painting to Charlie for a a few pounds. It later transpires that the painting is a masterpiece and worth many thousands of pounds. Whilst there was a loss to Bob's estate (a