Commentary

I3.147 Dispositions not intended to confer benefit examples

IHT, trusts and estates

I3.147 Dispositions not intended to confer benefit examples

I3.147 Dispositions not intended to confer benefit examples

A number of hypothetical situations may serve to illustrate the possible application of IHTA 1984, s 10.

Example 1

Where A sells S a 10% holding in his company and thereby loses control but obtains in return a price equal to the value of a 10% holding, the sale will have to satisfy both IHTA 1984, s 10(1) and (2), and it appears unlikely that this will be achieved, since HMRC will have to be satisfied that the price was or was equal to one that would have been freely negotiated between the parties if they had been

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