IHTM04067 - Lifetime transfers:
what is an immediately chargeable transfer?
Any lifetime transfer that does not qualify as a PET (
IHTM04057) will be immediately
chargeable to IHT under IHTA84/S3 (1). Two transfers that do not
qualify are a
- transfer into a discretionary trust,
because the gift is not to an individual or one of the specified
trusts, see
IHTM04058 (
IHTM04058), and
- transfer to a company, see example 2 at
IHTM04060
There may also be an alternative charge on the property
transferred under the GWR rules. (
IHTM04071)
There are four other transfers of value (
IHTM04024) that are specifically
prevented from being PETs. These are a
- transfer by a close company, (
IHTM04068) IHTA84/S94 (1),
- the deemed disposition on the alteration
in the capital or share rights (
IHTM04069) of close companies, IHTA/S98
(3),
- the release of a life interest (
IHTM04063) between 18 March 1986 and 16
March 1987, and
- the transfer of woodlands (
IHTM04062) subject to an outstanding
Estate Duty charge, which only qualifies for partial PET
treatment.
