IHTM04052 - Lifetime transfers: what is a person?

The disposition ( IHTM04023) has to be by 'a person'. In law, this includes a corporation or company as well as a natural person. However in relation to the charging provisions, this wide meaning is effectively cut down by the definition of a chargeable transfer. ( IHTM04027) To be chargeable, a transfer of value ( IHTM04024) has to be either

• by an individual, ( IHTM04053) that is a human being, or
• by a close company ( IHTM04068) and be treated under IHTA84/S94 to IHTA84/S102 as a transfer of value by an individual.