Commentary

I3.144 Commercial transactions for IHT―'arm's length'

IHT, trusts and estates

I3.144 Commercial transactions for IHT―'arm's length'

I3.144 Commercial transactions for IHT―'arm's length'

The second part of IHTA 1984, s 10(1) is where the taxpayer has to establish either (a) that it was made in a transaction at arm's length between persons not connected with each other, or (b) that it was such as might be expected to be made in a transaction at arm's length between persons not connected with each other.

Subsection (1)(a) is objective; the parties are or are not connected and the transaction was or was not at arm's length. The notion of an arm's length transaction is an elusive one. The fact

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