Commentary

I3.254 Calculating the value transferred — excluded property

IHT, trusts and estates

I3.254 Calculating the value transferred — excluded property

I3.254 Calculating the value transferred — excluded property

Excluded property consists essentially of reversionary interests under settlements satisfying certain conditions (see I5.701 onwards), and foreign property in foreign ownership (see Division I9.3).

For transfers of value on or after 3 December 2014, 'relevant decorations or awards' which have never been the subject of a disposition for a consideration in money or money's worth (including a disposition of part or of an interest in it)1 are excluded property. A 'relevant decoration or award' is defined to include awards that are:

  1.  

    •     designed to be worn to denote membership of an Order, including an Order outside the UK

  2.  

    •     awarded for valour of gallant conduct

  3.  

    •     made in connection with a person being a member of the armed forces or an emergency responder (see I4.210) of any country or territory, or

  4.  

    •     awarded by the crown or a country or territory outside the UK in connection with public service or achievement in public life (this will include awards such as OBEs etc).

Calculating the value transferred in relation to a disposition of excluded property presents certain problems. The rule is:

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