I6.126 Corporate transferees and IHT
Consider the following situation: A and B own equally the entire issued share capital of X Ltd, which has two wholly-owned subsidiaries, Y Ltd and Z Ltd. Under IHTA 1984, s 94, any transfer of value made by one of those companies to either of the others are apportioned (or sub-apportioned) equally between A and B. As the aggregate value of the three companies remains unchanged, neither A's estate, nor B's, is increased by such a transfer.
It follows that, in the absence of provisions to the contrary, a charge to tax would arise under IHTA
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