Commentary

I3.154 Dispositions allowable for income tax

IHT, trusts and estates

I3.154 Dispositions allowable for income tax

I3.154 Dispositions allowable for income tax

A disposition made by any person, including a company1, is not a transfer of value if it is allowable as a deduction in computing that person's profits or gains for income tax or corporation tax or if it would be so allowable if the profits or gains were sufficient to be so computed2.

This rule is not confined to expenses that may be set only against trading income but extends to all sums deductible in computing income, provided always that the income is chargeable to UK tax. This rule often excludes liability3 in respect of

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