Commentary

I3.262 Allowance for earlier transfers

IHT, trusts and estates

I3.262 Allowance for earlier transfers

I3.262 Allowance for earlier transfers

The second part of IHTA 1984, s 268(3) is designed to prevent double taxation. It provides that where any one or more of the earlier operations also constitute a transfer of value made by the same transferor, the value transferred by the earlier operations is taken as reducing the value transferred by all the operations taken together.

For the first part, the timing rule, see I3.132.

It will be noted that the allowance is for the value transferred by the transfer of value: it is not necessary that the earlier transfer should have been a chargeable transfer.

Example

In July 2014, D, whose total of chargeable transfers then stood at £350,000, transferred to the S discretionary trust property worth £10,000. The

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