Commentary

I3.328 Allocation of lifetime exemptions

IHT, trusts and estates

I3.328 Allocation of lifetime exemptions

I3.328 Allocation of lifetime exemptions

Where a transfer qualifies for any of the exemptions considered in I3.321–I3.327, various questions can arise as to the relationship with other reliefs and exemptions.

First, there is the question of how BPR and APR (see Divisions I7.1, I7.3) fit in with the exempt transfer rules such as those relating to the annual exemption. Here the structure of the reliefs makes the position clear. The reliefs reduce or exclude the value transferred so far as it is attributable to the property involved. It is only when the value attributable to the property has been reduced

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