IHTM04067 - Lifetime transfers: what is an immediately chargeable transfer?

Any lifetime transfer that does not qualify as a potentially exempt transfer (PET) (IHTM04057) will be immediately chargeable to Inheritance Tax under IHTA84/S3 (1). Two transfers that do not qualify are a

  • transfer into a relevant property trust, because the gift is not to an individual or one of the specified trusts, see IHTM04058 and
  • transfer to a company, see example 2 at IHTM04060

»Ê¹ÚÌåÓýappre may also be an alternative charge on the property transferred under the gift with reservation rules. (IHTM04071)

»Ê¹ÚÌåÓýappre are four other transfers of value (IHTM04024) that are specifically prevented from being PETs. »Ê¹ÚÌåÓýappse are a

  • transfer by a close company, (IHTM04068) IHTA84/S94 (1),
  • the deemed disposition on the alteration in the capital or share rights (IHTM04069) of close companies, IHTA/S98 (3),
  • the release of a life interest (IHTM04063) between 18 March 1986 and 16 March 1987, and
  • the transfer of woodlands (IHTM04062) subject to an outstanding Estate Duty charge, which only qualifies for partial PET treatment.