Commentary

I3.113 The persons that can make a transfer of value

IHT, trusts and estates

I3.113 The persons that can make a transfer of value

I3.113 The persons that can make a transfer of value

Although under IHTA 1984, s 2(1) a chargeable transfer is a transfer made by an individual, IHTA 1984, s 3(1) provides that a transfer of value is a disposition made by a 'person'.

A transfer of value can thus be made by a company, while a chargeable transfer cannot. In any legislation, in the absence of express contrary provision, 'person' includes a corporation1. The main point of bringing dispositions by companies into the definition of transfer of value is so that transfers of value made by a close company may be

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