Commentary

I3.731 Computation of the chargeable amount (intangible property)

IHT, trusts and estates

I3.731 Computation of the chargeable amount (intangible property)

I3.731 Computation of the chargeable amount (intangible property)

Where a pre-owned assets charge arises in respect of intangible property, the 'chargeable amount' in relation to the relevant property is N minus T, where1:

  1.  

         N is the amount of interest that would be payable for the taxable period if interest were payable at the prescribed rate on an amount equal to the value of the relevant property at the valuation date

  2.  

         T is the amount of any income tax or capital gains tax payable by the taxpayer in respect of the taxable period by virtue of any of a number of specified provisions, so far as the tax is attributable to the relevant property; the provisions in question are ITTOIA 2005, ss 461, 624, ITA 2007, ss 720–730 and TCGA 1992, ss 77, 86. ITTOIA 2005, s 624

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