IHTM42085 – Ten year anniversary:
the deemed transfer for rate
IHTA84/S66 provides that the charge is as if there is a
hypothetical transfer at the ten year anniversary (TYA) and the
values deemed to be transferred are the values of
1) Property on which tax is chargeable now
- Relevant property in the settlement,
valued on
the day before the TYA (
IHTM42161)
- Value net of AR/BR
Plus
2) Other aggregate property (Only for settlements made after 27
March 1974):
- Any property in the settlement which is
not relevant property, valued at the date it was
put into the settlement. This is known as the historic value.
(This reflects any part of the fund that might be an interest in
possession or have A&M powers, for example.)
and
- Any
related trusts valued at the time they were set
up. (
IHTM42230). Also the historic
value.
The overall total is the assumed chargeable transfer for
calculating the rate of tax.
