Commentary

I7.193 BPR clawback—meaning of transferee

IHT, trusts and estates

I7.193 BPR clawback—meaning of transferee

I7.193 BPR clawback—meaning of transferee

The term 'transferee' does not have any general meaning in the IHT legislation, because it gives the terms 'transfer' and 'transferor' artificial meanings unlike their ordinary language meanings; a transfer for the purposes of the legislation is an act or omission of the transferor which diminishes the value of his estate, but it does not necessarily involve him in transferring any property to another person. For further information on 'transfer of value' see I3.111.

Accordingly, for the purposes of the conditions described in I7.192 there is a special definition of the transferee in relation to any

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