Commentary

I3.554 Lifetime transfers reported late—exemptions

IHT, trusts and estates

I3.554 Lifetime transfers reported late—exemptions

I3.554 Lifetime transfers reported late—exemptions

Where a transfer is reported late special provision1 is made for the application of limited exemptions, ie, the annual exemption and the exemption for disposals to non-UK domiciled spouses. This special rule applies where IHT has been accepted on the later transfer on the basis that it falls partly within the exemption limit and the earlier transfer would have fallen wholly or partly within the same exemption if it had been reported in time. The rule allocates the exemption to the later transfer.

Example

In May A gives X £3,000; the transfer is not reported.

In June A

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