IHTM04025 - Structure of the
charge: what is a deemed transfer of value?
A deemed transfer of value is one that is imposed by statute on
a particular event or series of events. In general, the IHT
legislation applies to deemed transfers of value in the same way as
it does to actual transfers of value, but
- certain exemptions – mainly lifetime
exemptions (
IHTM14131) – may not apply
- reliefs which say that a particular event
shall not be a transfer of value (
IHTM04151) cannot apply, and
- the value transferred may not be
established by reference to the loss to transferor’s estate.
(
IHTM04054)
Events that are deemed to be transfers of value are
- on death, (
IHTM04041)
- the termination or disposal of an interest
in possession in settled property, (
IHTM04083)
- a transfer by a close company, (
IHTM04067)
- property ceasing to be subject to a
reservation of benefit in the donor’s lifetime (
IHTM04064) which is a deemed PET,
- the discharge or reduction of a debt
subject to abatement (
IHTM04064) under FA86/S103, which is a
deemed PET.
