I3.603 Income tax

I3.603 Income tax

Where a disposition is allowable in computing the profits of the disponer for income (or corporation tax) purposes, that disposition is not a transfer of value for IHT purposes1.

Where, however, a disposition gives rise to a charge to income tax in the hands of the disponer, for example a gift of trading stock treated as a disposal of that stock at its market value2, that disposition may also be a chargeable transfer. Any income tax arising on a transfer of value and borne by the transferor would not be taken into account in determining the value of

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