Commentary

I5.227 Transactions by trustees of QIIPs

IHT, trusts and estates

I5.227 Transactions by trustees of QIIPs

I5.227 Transactions by trustees of QIIPs

Where there is a diminution in the value of settled property subject to an interest in possession as the result of a transaction between the trustees and certain other qualifying persons (see below) there is a deemed transfer of value by the life tenant. The diminution is treated as if it were the termination of an interest in possession in a part of the settled property of a value equal to the diminution in value1.

Value of transfer

The value deemed to be transferred will be equal to the diminution in value caused by the transaction. Not all exceptions from charge will be capable of applying. As the transaction is not a disposal of part of the interest in possession there can be no reduction2 for consideration received (see I5.226). Nor is it obvious that the exemption from charge3

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