Commentary

I3.257 'Back to back' arrangements

IHT, trusts and estates

I3.257 'Back to back' arrangements

I3.257 'Back to back' arrangements

Where the purchase of an annuity in conjunction with a life policy constitutes a transfer of value, the value transferred is the lesser of:

  1.  

    •     the aggregate of the consideration given for the annuity and any premium paid or other consideration given under the policy (whether on or before the transfer of value)

  2.  

    •     the value of the greatest benefit capable of being conferred at any time by the policy calculated as if that time were the date of the transfer1.

Such 'back to back' arrangements are discussed fully in I3.118

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