IHTM14871 - Future payments: introduction

IHTA84/S262 provides the machinery for charging tax in cases where a disposition is made

• for partial consideration

and

• the transferor satisfies their part of the bargain wholly or partly
• more than a year after it is made.

Regard the element of bounty in each payment (the chargeable proportion ( IHTM14872)) made by the transferor, or each transfer of assets made by him, as a separate disposition and tax it accordingly.

Refer any case involving the possible application of IHTA84/S262 or any enquiry as to its application to Technical Group. You will probably also need to ask the BAO to consider the value of the future payments at the date of the disposition (see the example on the next page).