Commentary

I3.318A Exclusions from potential exemption

IHT, trusts and estates

I3.318A Exclusions from potential exemption

I3.318A Exclusions from potential exemption

A transfer cannot be a potentially exempt transfer (PET) if, under any provision of IHTA 1984, tax is charged as if a transfer of value had been made1. This rule does not however apply in the case of a tax charge on the termination of an interest in possession except where the transfer of value on the termination is in relation to any interest in possession acquired by a UK domiciliary after 8 December 2009 by virtue of a transaction that was not intended to confer gratuitous benefit. This therefore excludes the making of a transfer of value by a close company which is apportioned to the participators under the rules detailed

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