Since in general, inheritance tax is chargeable on transfers
made by individuals, there could be considerable scope for a person
to avoid tax by effecting transfers through the medium of
companies. Such transactions are less likely with the introduction
of PETs and 100% business relief.
To limit such avoidance the provisions at IHTA84/S94 through to IHTA84/S102 lift the corporate veil and
Refer to SAV, who are responsible for all decisions in
connection with the application of the legislation. They will
determine what is a “close company” and who is a
IHTA84/S102 (1) says that a close company is defined as within the meaning of the Corporation Tax Acts. In general terms, it is a UK registered company with 5 or less participants/directors.