Commentary

I5.225 Disposals of QIIPs generally

IHT, trusts and estates

I5.225 Disposals of QIIPs generally

I5.225 Disposals of QIIPs generally

Where a person entitled to a QIIP (often called the 'life tenant') disposes of his interest, the disposal is not a transfer of value but is treated as the coming to an end of his interest1 and tax is charged accordingly — see I5.2212.

The disposal does not need to be effected by the life tenant — it could be a disposal by the trustees. A disposal that typically comes into this category is an appointment of capital to a remainderman of a 'flexible life interest trust'. The terms of the settlement may not even

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