Commentary

I7.170A BPR on gifts with reservation example

IHT, trusts and estates

I7.170A BPR on gifts with reservation example

I7.170A BPR on gifts with reservation example

Example

X had for many years held 49% of the shares of Z Ltd, an unquoted trading company. On 17 August 2014 X gave a 20% holding to his brother B, conditional on X continuing to receive the same salary despite ceasing to perform any duties for the company.

X retained the other 29% shareholding, but died on 22 February 2016, at which time B still held the shares received from X.

The gift from X to B on 17 August 2014 is a potentially exempt transfer, being a gift with reservation on which 100%

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