Commentary

I4.323 Sale of related property — definition of a qualifying sale

IHT, trusts and estates

I4.323 Sale of related property — definition of a qualifying sale

I4.323 Sale of related property — definition of a qualifying sale

A sale is a qualifying sale if the following conditions are satisfied:

  1.  

    (a)     the vendors are the persons in whom the relevant property (see I4.321) vested immediately after the death or the deceased's personal representatives (sales by beneficiaries do not therefore qualify). The word 'vested' here is interpreted by HMRC as meaning 'was vested' so as to include continuing trustees who held the property before the death as well as after it1

  2.  

    (b)     it is an arm's length sale for a price freely negotiated at the time of the

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