Commentary

I3.318 Effect of a PET while the transferor is living

IHT, trusts and estates

I3.318 Effect of a PET while the transferor is living

I3.318 Effect of a PET while the transferor is living

A transfer that is wholly or partly potentially exempt will, to the extent that it is a potentially exempt transfer (PET), be treated as if it were an exempt transfer for all purposes so long as the transferor is alive1. This means, in particular, that while the transferor is alive no tax is payable on it and no account in respect of it needs to be or should be delivered to HMRC2, and it is not aggregable with any subsequent immediately chargeable transfers (ie ones not potentially exempt) when calculating the IHT on the latter. For an example of this see I3.511.

However, to enable HMRC to quantify any lifetime immediately chargeable transfers they will need

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