Commentary

I7.324 APR and successive transfers

IHT, trusts and estates

I7.324 APR and successive transfers

I7.324 APR and successive transfers

The seven-year ownership (or two year occupation) condition can be satisfied where either the transferor acquired the property in question on a death, or the transfer in respect of which relief is claimed was made on the transferor's death or both occurred on a death1.

The result is that if A leaves agricultural property on his death to B, a subsequent transfer of the property by B can qualify for relief even if made less than seven (or two) years after A's death. Also, if C makes a lifetime transfer to D and D dies within the seven (or two) years the appropriate reduction can be made on D's death.

The full requirements2 are:

  1.  

    (1)     two transfers of value (an earlier

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