IHTM25331 - Successive transfers: Introduction


The ownership test ( IHTM25301) is not satisfied if the business property was not owned by the transferor ( IHTM25302) throughout the two years immediately preceding the transfer.

However, you can still treat the test as satisfied if there was an earlier transfer of value and certain conditions are met, IHTA84/S109 (1).

These conditions are summarised in a chart ( IHTM25332).

Note that the succession provisions ( IHTM25321) do not apply to IHTA84/S109.