I5.226 Disposals of QIIPs for consideration
Where a person beneficially entitled to an interest in possession in settled property (the life tenant) disposes of his interest for consideration in money or money's worth, the disposal is not a transfer of value but is treated as the coming to an end of his interest1. Tax is charged (I5.221) as if the value of the property in which the interest subsisted were reduced by the amount of the consideration2.
A, who is the life tenant of a fund worth £350,000, assigned his life interest in July 2018 in consideration of a payment to him of £75,000. The assignment is a potentially exempt transfer, which will become chargeable by reason of A's death within seven years. The value transferred is the value of the fund, less the consideration, £350,000 – £75,000 = £275,000.
In determining the amount of consideration the value of a reversionary interest in the property or of any interest in other property comprised in the same settlement is left out of