shows the shares subject to the present transfer. If the
transfer was made to more than one transferee or more than one
transfer was involved, the separate parcels of shares transferred
and the order in which the transfers were made (if known) will be
shown. If the transfers were made on the same day, the order in
which they are taken for IHT purposes may, in certain
circumstances, affect the value transferred and the provisions of
s.266(1) IHTA 1984 should be kept in mind. Whether the value
offered is for the holding or represents the value transferred will
also be indicated in the appropriate box in the heading.
Section 2 shows the retained shareholdings.
Section 4 indicates the reliefs claimed by the
agents. If a particular relief has not been claimed on the whole of
the value transferred, details should be shown in Section 11 below.
Availability of business relief, agricultural relief,
instalments and interest relief must be considered in all cases
at an early stage, whether the relief has been
claimed or not. See Chapter 111 of this manual
SVM111000 for Business Relief and
Chapter 112 of this manual for Agricultural Relief
SVM112000.
Section 4, besides indicating whether BR/AR and instalments
are claimed, should state the amount of annual exemption ('AE')
available against the present transfer of value.
Section 5 will include information relevant to BR
claims (if appropriate).
Section 7 For events before 22 March 2006 this
section asks if the transfer is one out of a trust in which the
transferor had an interest in possession immediately before the
transfer - e.g. a release of a life interest by the life tenant.
The answer will always be 'no' unless the gift is out of settled
property in which the transferor had an interest in possession
before the transfer. For events after 22 March 2006 and a
‘yes’ answer has been given, valuers should consult the
Inheritance Tax manual at IHTM16061 onwards for guidance on the IHT
treatment of beneficial interests in possession, where the interest
arose on or after 22 March 2006.
Section 8 has three boxes. These are for details
of the aggregate chargeable transfers, the taxable limit and the
contribution of the present chargeable transfer to the aggregate
chargeable transfer figure.
Where the transferor has
died, the 'aggregate chargeable transfers' will be
the aggregate transfers chargeable at the death (e.g. failed PETS
£100,000, chargeable death estate £400,000; therefore,
aggregate chargeable transfers £500,000) and the 'taxable
limit' will be the threshold at the date of death.
Where the transferor is
alive and the transfer is one which is chargeable
when made, aggregate chargeable transfers will include the
chargeable value of the present chargeable transfer plus the value
of
chargeable transfers (not PETs) made within the
previous 7 years - and the taxable limit will be the threshold at
the date of the present transfer.
The third box at Section 8 asks for the net contribution of
the present chargeable transfer to the aggregate chargeable
transfers figure. This means the present chargeable transfer in so
far as it relates to the shares. If 100% BR is claimed, the figure
will be nil. If no BR is due and if the value of the transferred
shares is included in the IHT 100 Account at £20,000 and
£3,000 AE is available, the net figure in the third box will
be £17,000. [This would still be the appropriate figure, even
if cash and quoted investments worth, say, £300,000 were
transferred at the same time.]
Section 9 shows whether any valuation or other
relevant information has been supplied by the parties.
Section 10 In addition where there have been
transfers of shares by the same transferor in other companies, made
at any time, this Section will give the company names and CRNs if
known. Where other valuations are still in progress, the present
valuation will normally be divided to the same valuer as a multi
case, in the interests of cost-effectiveness and customer service.
If this is not done, the matter should be referred to the Team
Leader to consider whether re-allocation is needed. The multi
procedure also applies to Death and Settlement references.
Section 11 lists any other information or special
instructions sent.
| Additional Guidance: SVM150000 |
