»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýapp loss to the transferor’s estate (IHTM04054) is less than the value of the property (IHTM04030) given if the property given

• remains part of the deceased’s estate, (IHTM04029)
• includes excluded property, (IHTM04251) or
• if the transferee pays the expenses (other than any Inheritance Tax on the transfer) incurred by the transferor in making the transfer, IHTA84/S164.

Example 1

Prior to 22 March 2006 if Ali had transferred £200,000 into a settlement where the trusts were for her for life with remainder over, the £200,000 would have remained part of Ali’s estate. This is because the transfer was to a ‘qualifying� interest in possession settlement, so although there is a disposition, (IHTM04023) there is no loss to the estate and no transfer of value. (IHTM04024)

From 22 March 2006, the transfer would now be an immediately chargeable transfer because it would be a transfer to a relevant property trust, and in addition the gift with reservation provisions under FA86/S102 would also apply (IHTM14315).

Example 2

Under the Will of Tamsin, property is settled on Seren for life with remainder to Ruby. Ruby gives the reversionary interest (IHTM16084) to Seren. »Ê¹ÚÌåÓýapp reversion is an item of property which has value. But it is excluded from the charge (IHTM04281) which is disregarded in considering whether the disposition has given rise to a loss to Ruby’s estate. »Ê¹ÚÌåÓýapp disposition is not a transfer of value.