Under IHTA84/S52(2), if an interest in possession comes to an
end by being disposed of by the person entitled to it, and the
disposal is for a consideration in money or money’s worth,
tax shall be charged under S52 as if the value of the property in
which the interest subsisted were reduced by the amount of the
consideration.
But in determining the amount of the consideration the value
of any reversionary interest in the property in which the IIP
subsists, or any interest, reversionary or otherwise, in other
property comprised in the same settlement, shall be left out of
account.
This provision applies to cases under IHTA84/S51 (1) and not
the more common ‘coming to an end of an interest’ under
S52 (1). However, where the person became beneficially entitled to
the interest in possession on or after 22 March 2006, IHTA84/S52(2)
will only apply if it an immediate post-death interest, a disabled
person’s interest or a transitional serial interest,
S52(2A).
