The legislation also provides that the following transfers shall be treated as if they were PETs. ( IHTM04057) This means that the individual ( IHTM04053) has made a PET and not simply a transfer of value so the conditions to qualify as a PET do not have to be considered. The transfers are
Because these transfers are deemed to be PETs, and a PET is
transfer of value (
IHTM04024) that would, apart from
IHTA84/S3A be a chargeable transfer, (
IHTM04027) they join the charging
structure as chargeable transfers. This means that no exemptions (
IHTM11000) may be deducted.
The same would apply for reliefs such as agricultural relief
(
IHTM24000) and business relief (
IHTM26000). However, these reliefs are
specifically available against the deemed PET that arises on the
cessation of reservation (FA86/SCH20/PARA8). However, there is no
corresponding provision for the reduction of a debt subject to
abatement. Any transfer made in this way is not entitled to any
exemptions or reliefs.
