Commentary

I5.223 Lifetime termination of QIIP — part interest

IHT, trusts and estates

I5.223 Lifetime termination of QIIP — part interest

I5.223 Lifetime termination of QIIP — part interest

References in I5.221 and in the exemption provisions in I5.251 to any property or to an interest in any property include references to part of any property or to part of an interest in any property1. Furthermore, the IHT chargeable under these provisions on the coming to an end of part of a QIIP is charged as if the value of the property (or part) in which the interest subsisted were a corresponding part of the whole2.

The operation of this is clear in a case where a life tenant in, say, half the income

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