Commentary

I3.158 Exclusions to dispositions for IHT―waiver of dividends

IHT, trusts and estates

I3.158 Exclusions to dispositions for IHT―waiver of dividends

I3.158 Exclusions to dispositions for IHT―waiver of dividends

A waiver of any dividend on shares of a company is not a transfer of value if it is made within 12 months before the right to the dividend accrues1.

If dividends are to be waived for a number of years there must be an agreement to waive followed by annual waivers, but if such an agreement is made as part of a bona fide commercial agreement and is not intended to confer a gratuitous benefit, it will be exempt under the provisions of IHTA 1984, s 10 (see I3.141–I3.148).

This relief is restricted

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