IHTM14161 - Transfer of part of a property: summary

Annual transfers of part of a property are sometimes referred to as "salami slices".

The scheme falls into four broad categories

• The transfer of a sum of money (IHTM14162)
• The transfer of a share equal in value to a sum of money (IHTM14163)
• Transfer of shares quantified by loss in value (IHTM14164)
• Property on trust for sale and proceeds split between transferor and transferee (IHTM14165)

If the deed does not fit precisely into one of the categories, refer the case to Technical Group to liaise with the Valuation Office (IHTM23002) as to the manner of reference required, or to your manager if tax avoidance appears to be in view.

Before full investigation, it is important that you check what exemptions and reliefs are due against the death estate and generally to consider whether any adjustment to the values offered will be worthwhile.

For any of the above categories, you must establish the facts, and obtain copies of the documentation by which the transfers were effected (a copy of the first transfer will normally be sufficient to begin with). You may also need to consider by whom and on what basis the property was occupied between the first transfer and the transferor's death.

(This text has been withheld because of exemptions in the Freedom of Information Act 2000)