Commentary

I3.744 Reliefs in respect of double taxation

IHT, trusts and estates

I3.744 Reliefs in respect of double taxation

I3.744 Reliefs in respect of double taxation

Where in any year of assessment a taxpayer faces a pre-owned assets charge on land or a chattel, and also faces a charge on intangible property which derives its value in whole or part from the same land or chattel, he is charged only under the provision which produces the higher chargeable amount1. Where this relief applies, only the provision under which he is actually charged is taken into account in determining the aggregate of amounts for the purposes of the de minimis exemption2.

This provides a measure of relief where, for example, an

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