IHTM04051 - Lifetime transfers: the charging provisions
The basic provision governing the tax charge on lifetime transfers is IHTA84/S3 (1). The charge may be divided into three parts. The subsection provides that a transfer of value is
- a disposition, ( IHTM04023)
- made by a person, ( IHTM04052)
- as a result of which the value of his estate immediately after the disposition is less than it would be by the disposition, ( IHTM04054)
The value of the transferor’s estate before the transfer
excludes any excluded property, (
IHTM04251) IHTA84/S3 (2).
Most lifetime transfers are potentially exempt transfers
(PETs), (
IHTM04057) that is they are only
chargeable if the transferor dies within seven years of making the
transfer, IHTA84/S3A (1) and (4). But a lifetime transfer may be
chargeable as
