IHTM14000 - Lifetime transfers: contents

Introduction

1. IHTM14001

   Introduction

Basis of valuation

1. IHTM14011

   Basis of valuation: Summary
2. IHTM14012

   Basis of valuation: Burden of tax
3. IHTM14013

   Basis of valuation: Treatment of expenses

Specific lifetime exemptions

1. IHTM14131

   Specific lifetime exemptions: Summary
2. IHTM14132

   Specific lifetime exemptions: Order in which exemptions apply

Annual exemption

1. IHTM14141

   Annual exemption: Summary
2. IHTM14142

   Annual exemption: Relievable property
3. IHTM14143

   Annual exemption: Multiple transfers
4. IHTM14144

   Annual exemption: Roll over provisions

Schemes to exploit annual exemption

1. IHTM14151

   Schemes to exploit annual exemption: Introduction
2. IHTM14152

   Schemes to exploit annual exemption: Transfer by sale
3. IHTM14161

   Schemes to exploit annual exemption: Transfer of part of a property
4. IHTM14162

   Schemes to exploit annual exemption: Transfer of sum of money
5. IHTM14163

   Schemes to exploit annual exemption: Transfer of share equal to a sum of money
6. IHTM14164

   Schemes to exploit annual exemption: Transfer of shares quantified by loss in value
7. IHTM14165

   Schemes to exploit annual exemption: Split proceeds from property on trust for sale

Small gifts exemption

1. IHTM14180

   Small gifts exemption: Summary

Gifts in consideration of marriage or registration of civil partnership

1. IHTM14191

   Gifts in consideration of marriage or registration of civil partnership: Summary
2. IHTM14193

   Gifts in consideration of marriage or registration of civil partnership: Permissible beneficiaries for s.22 purposes
3. IHTM14201

   Gifts in consideration of marriage or registration of civil partnership: Rennell v IRC
4. IHTM14202

   Gifts in consideration of marriage or registration of civil partnership: Rennell v IRC - gifts by way of settlement
5. IHTM14211

   Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - outright gifts and other dispositions
6. IHTM14212

   Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - the eventual recipient
7. IHTM14213

   Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - IHTA84/S22 (4)(b) provisions
8. IHTM14214

   Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - payments under covenant
9. IHTM14220

   Gifts in consideration of marriage or registration of civil partnership: Relationship with spouse or civil partner exemptions
10. IHTM14221

    Gifts in consideration of marriage or registration of civil partnership: Termination of IIP in settled property

Normal expenditure out of income

1. IHTM14231

   Normal expenditure out of income: Introduction
2. IHTM14235

   Normal expenditure out of income: Life policy linked with an annuity
3. IHTM14236

   Normal expenditure out of income: Loans

Conditions for normal out of income exemption

1. IHTM14241

   Conditions for normal out of income exemption: Normal expenditure
2. IHTM14242

   Conditions for normal out of income exemption: Pattern of gifts
3. IHTM14243

   Conditions for normal out of income exemption: Factors to consider
4. IHTM14244

   Conditions for normal out of income exemption: Case Law - Bennett v IRC
5. IHTM14250

   Conditions for normal out of income exemption: Out of income
6. IHTM14251

   Conditions for normal out of income exemption: Case Law - McDowall
7. IHTM14255

   Conditions for normal out of income exemption: Transferor's standard of living

Gifts with reservation (GWRs)

1. IHTM14301

   Gifts with reservation (GWRs): Requirements for a GWR
2. IHTM14303

   Gifts with reservation (GWRs): Devolution of GWR property

Gifts with reservation (GWRs): The gift

1. IHTM14311

   Gifts with reservation (GWRs): The gift: Initial requirements
2. IHTM14312

   Gifts with reservation (GWRs): The gift: The donor
3. IHTM14313

   Gifts with reservation (GWRs): The gift: The property given
4. IHTM14314

   Gifts with reservation (GWRs): The gift: Examples of the property given - carve-out arrangements
5. IHTM14315

   Gifts with reservation (GWRs): The gift: Defining the gift
6. IHTM14316

   Gifts with reservation (GWRs): The gift: Sales for less than full consideration
7. IHTM14317

   Gifts with reservation (GWRs): The gift: Interest free loans
8. IHTM14318

   Gifts with reservation (GWRs): The gift: Exempt transfers which cannot be GWRs
9. IHTM14319

   Gifts with reservation (GWRs): The gift: Exempt transfers which can be GWRs

Gifts with reservation (GWRs): The reservation

1. IHTM14331

   Gifts with reservation (GWRs): The reservation: Initial requirements
2. IHTM14332

   Gifts with reservation (GWRs): The reservation: Possession and enjoyment by the donee
3. IHTM14333

   Gifts with reservation (GWRs): The reservation: Exclusion of the donor
4. IHTM14334

   Gifts with reservation (GWRs): The reservation: Examples of exclusion of the donor
5. IHTM14335

   Gifts with reservation (GWRs): The reservation: Non-exclusion need not be continuous
6. IHTM14336

   Gifts with reservation (GWRs): The reservation: Effect of consideration
7. IHTM14337

   Gifts with reservation (GWRs): The reservation: Continuation of reasonable commercial arrangements
8. IHTM14338

   Gifts with reservation (GWRs): The reservation: Benefit by associated operations
9. IHTM14339

   Gifts with reservation (GWRs): The reservation: Benefit to donor's spouse or civil partner
10. IHTM14340

    Gifts with reservation (GWRs): The reservation: When occupation is not a reservation
11. IHTM14341

    Gifts with reservation (GWRs): The reservation: Full consideration in cases of land and chattels
12. IHTM14342

    Gifts with reservation (GWRs): The reservation: Infirm relative
13. IHTM14343

    Gifts with reservation (GWRs): The reservation: Annual exemption
14. IHTM14360

    Gifts with reservation (GWRs): The reservation: Interests in land

Gifts with reservation (GWRs): Tracing

1. IHTM14371

   Gifts with reservation (GWRs): Tracing: Introduction
2. IHTM14372

   Gifts with reservation (GWRs): Tracing: Absolute gifts of cash
3. IHTM14373

   Gifts with reservation (GWRs): Tracing: Absolute gifts of property other than cash
4. IHTM14374

   Gifts with reservation (GWRs): Tracing: Supplementary provisions

Gifts with reservation (GWRs): Settled property

1. IHTM14391

   Gifts with reservation (GWRs): Settled property: Introduction
2. IHTM14392

   Gifts with reservation (GWRs): Settled property: The donee and the property given
3. IHTM14393

   Gifts with reservation (GWRs): Settled property: Settlement on discretionary trusts
4. IHTM14394

   Gifts with reservation (GWRs): Settled property: Donor also a trustee
5. IHTM14395

   Gifts with reservation (GWRs): Settled property: Reasonable commercial arrangements
6. IHTM14396

   Gifts with reservation (GWRs): Settled property: Settlement created when the settlor is domiciled outside the UK

Gifts with reservation (GWRs): Tracing settled property

1. IHTM14401

   Gifts with reservation (GWRs): Tracing settled property: The property comprised in the gift
2. IHTM14402

   Gifts with reservation (GWRs): Tracing settled property: If the property ceases to be settled
3. IHTM14403

   Gifts with reservation (GWRs): Tracing settled property: Settlement by the donee

Gifts with reservation (GWRs): Insurance policies

1. IHTM14421

   Gifts with reservation (GWRs): Insurance policies: Introduction
2. IHTM14431

   Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: General gifts after 18 March 1986
3. IHTM14432

   Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Normal out of income exemption on regular premiums
4. IHTM14433

   Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Policies made before 18 March 1986
5. IHTM14434

   Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Automatic increases in policy value
6. IHTM14435

   Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Change in life assured
7. IHTM14440

   Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: The property given

Gifts with reservation (GWRs): The reservation on insurance policies

1. IHTM14451

   Gifts with reservation (GWRs): The reservation on insurance policies: Introduction
2. IHTM14452

   Gifts with reservation (GWRs): The reservation on insurance policies: Special rule for policies with linked benefits
3. IHTM14453

   Gifts with reservation (GWRs): The reservation on insurance policies: Reservation examples

The charge to tax

1. IHTM14502

   The charge to tax: Cumulation
2. IHTM14503

   The charge to tax: Cumulation with the death estate

The charge to tax: Potentially exempt transfers (PETs)

1. IHTM14511

   The charge to tax: Potentially exempt transfers (PETs): Tax treatment of a PET
2. IHTM14512

   The charge to tax: Potentially exempt transfers (PETs): Tax treatment of a PET followed by death
3. IHTM14513

   The charge to tax: Potentially exempt transfers (PETs): Cumulation
4. IHTM14514

   The charge to tax: Potentially exempt transfers (PETs): Cumulating transfers more than seven years before death
5. IHTM14515

   The charge to tax: Potentially exempt transfers (PETs): IHT nil rate band
6. IHTM14516

   The charge to tax: Potentially exempt transfers (PETs): Rate of tax
7. IHTM14517

   The charge to tax: Potentially exempt transfers (PETs): Taper relief
8. IHTM14518

   The charge to tax: Potentially exempt transfers (PETs): Fall in value relief
9. IHTM14519

   The charge to tax: Potentially exempt transfers (PETs): Special rate

The charge to tax: Immediately chargeable transfers

1. IHTM14531

   The charge to tax: Immediately chargeable transfers: Introduction
2. IHTM14532

   The charge to tax: Immediately chargeable transfers: Value for tax
3. IHTM14533

   The charge to tax: Immediately chargeable transfers: Cumulation
4. IHTM14534

   The charge to tax: Immediately chargeable transfers: Rate of tax

The charge to tax: Grossing

1. IHTM14541

   The charge to tax: Grossing: When to gross-up
2. IHTM14542

   The charge to tax: Grossing: When not to gross-up
3. IHTM14543

   The charge to tax: Grossing: Partial grossing
4. IHTM14544

   The charge to tax: Grossing: The grossing calculation
5. IHTM14545

   The charge to tax: Grossing: Tax paid after death of the transferor
6. IHTM14546

   The charge to tax: Grossing: Settled property
7. IHTM14547

   The charge to tax: Grossing: Authority for grossing

The charge to tax: Other charges

1. IHTM14550

   The charge to tax: Other charges: Late reported transfers
2. IHTM14551

   The charge to tax: Other charges: Death subsequent to the transfer

The charge to tax: Additional charges

1. IHTM14571

   The charge to tax: Additional charges: Introduction
2. IHTM14572

   The charge to tax: Additional charges: Value for tax
3. IHTM14573

   The charge to tax: Additional charges: Cumulation
4. IHTM14574

   The charge to tax: Additional charges: Rate of tax
5. IHTM14575

   The charge to tax: Additional charges: Taper relief
6. IHTM14576

   The charge to tax: Additional charges: The additional tax payable
7. IHTM14577

   The charge to tax: Additional charges: The additional tax payable (example 1)
8. IHTM14578

   The charge to tax: Additional charges: The additional tax payable (example 2)

The charge to tax: Reliefs

1. IHTM14579

   The charge to tax: Reliefs: Business relief and agricultural relief
2. IHTM14580

   The charge to tax: Reliefs: Fall in value relief

The charge to tax: The charge on lifetime transfers

1. IHTM14590

   The charge to tax: The charge on lifetime transfers: Gifts with reservation (GWRs)
2. IHTM14591

   The charge to tax: The charge on lifetime transfers: Simultaneous and same day transfers
3. IHTM14592

   The charge to tax: The charge on lifetime transfers: Liability for payment of tax
4. IHTM14593

   The charge to tax: The charge on lifetime transfers: Grossing-up the values
5. IHTM14595

   The charge to tax: The charge on lifetime transfers: Late reported transfers

Specific lifetime reliefs: Taper relief

1. IHTM14611

   Specific lifetime reliefs: Taper relief: When the relief applies
2. IHTM14612

   Specific lifetime reliefs: Taper relief: Quantifying the relief
3. IHTM14613

   Specific lifetime reliefs: Taper relief: Period of survival

Specific lifetime reliefs: Fall in value relief

1. IHTM14621

   Specific lifetime reliefs: Fall in value relief: Introduction
2. IHTM14622

   Specific lifetime reliefs: Fall in value relief: Form of the relief
3. IHTM14624

   Specific lifetime reliefs: Fall in value relief: Conditions for relief
4. IHTM14625

   Specific lifetime reliefs: Fall in value relief: What is a qualifying sale?
5. IHTM14626

   Specific lifetime reliefs: Fall in value relief: What is market value?
6. IHTM14627

   Specific lifetime reliefs: Fall in value relief: The claim
7. IHTM14628

   Specific lifetime reliefs: Fall in value relief: Wasting assets
8. IHTM14629

   Specific lifetime reliefs: Fall in value relief: Portfolio of assets
9. IHTM14630

   Specific lifetime reliefs: Fall in value relief: More than one sale
10. IHTM14631

    Specific lifetime reliefs: Fall in value relief: Not all of the transferred assets are sold

Specific lifetime reliefs: Shares and securities

1. IHTM14641

   Specific lifetime reliefs: Shares and securities: Adjustments
2. IHTM14642

   Specific lifetime reliefs: Shares and securities: Capital receipts
3. IHTM14643

   Specific lifetime reliefs: Shares and securities: Payment of calls
4. IHTM14644

   Specific lifetime reliefs: Shares and securities: Changes in shareholdings
5. IHTM14645

   Specific lifetime reliefs: Shares and securities: Transactions of close companies

Specific lifetime reliefs: Interests in land

1. IHTM14661

   Specific lifetime reliefs: Interests in land: Changes between transfer and death
2. IHTM14662

   Specific lifetime reliefs: Interests in land: Changes that have reduced the value
3. IHTM14663

   Specific lifetime reliefs: Interests in land: Changes that have increased the value
4. IHTM14664

   Specific lifetime reliefs: Interests in land: Compensation
5. IHTM14670

   Specific lifetime reliefs: Interests in land: Leases
6. IHTM14671

   Specific lifetime reliefs: Interests in land: Other property

Double charges relief

1. IHTM14691

   Double charges relief: When double charges arise
2. IHTM14692

   Double charges relief: Applying the relief
3. IHTM14693

   Double charges relief: Authority for the relief

Double charges relief: Potentially exempt transfers (PETs)

1. IHTM14701

   Double charges relief: Potentially exempt transfers (PETs): When double charges relief arises
2. IHTM14702

   Double charges relief: Potentially exempt transfers (PETs): Partial consideration
3. IHTM14703

   Double charges relief: Potentially exempt transfers (PETs): Property representing the property transferred
4. IHTM14704

   Double charges relief: Potentially exempt transfers (PETs): Calculations
5. IHTM14705

   Double charges relief: Potentially exempt transfers (PETs): Quick succession relief (QSR)

Double charges relief: Gifts with reservation (GWRs)

1. IHTM14711

   Double charges relief: Gifts with reservation (GWRs): When double charges relief arises
2. IHTM14712

   Double charges relief: Gifts with reservation (GWRs): Calculations
3. IHTM14713

   Double charges relief: Gifts with reservation (GWRs): Example of calculations 1
4. IHTM14714

   Double charges relief: Gifts with reservation (GWRs): Example of calculations 2

Double charges relief: Disallowed debts

1. IHTM14721

   Double charges relief: Disallowed debts: When double charges relief arises
2. IHTM14722

   Double charges relief: Disallowed debts: Calculations
3. IHTM14730

   Double charges relief: Disallowed debts: Transfers chargeable when made
4. IHTM14731

   Double charges relief: Disallowed debts: Calculations producing the same amount
5. IHTM14732

   Double charges relief: Disallowed debts: Discretionary trusts

Omissions

1. IHTM14802

   Omissions: Possible omissions of lifetime transfers
2. IHTM14810

   Omissions: Omission to exercise a right

Associated operations

1. IHTM14821

   Associated operations: Why are the provisions necessary?
2. IHTM14822

   Associated operations: Definition
3. IHTM14823

   Associated operations: The objective test
4. IHTM14824

   Associated operations: The subjective test
5. IHTM14825

   Associated operations: Additional provisions
6. IHTM14826

   Associated operations: Definition of terms
7. IHTM14827

   Associated operations: Transfer of value made by associated operations
8. IHTM14828

   Associated operations: Restrictions on association
9. IHTM14829

   Associated operations: Re Macpherson
10. IHTM14830

    Associated operations: Insurance policies
11. IHTM14831

    Associated operations: Gifts With Reservation
12. IHTM14832

    Associated operations: Transfers involving relievable property
13. IHTM14833

    Associated operations: Gifts between spouses or civil partners
14. IHTM14834

    Associated operations: Sale without immediate payment of the purchase price
15. IHTM14835

    Associated operations: Transfer in stages
16. IHTM14836

    Associated operations: Successive settlements

Transfers by close companies

1. IHTM14851

   Transfers by close companies: Introduction
2. IHTM14852

   Transfers by close companies: Transfers of value
3. IHTM14853

   Transfers by close companies: Exemptions
4. IHTM14854

   Transfers by close companies: Foreign aspects
5. IHTM14855

   Transfers by close companies: Alterations in share capital, loan capital or rights
6. IHTM14856

   Transfers by close companies: Liability to tax

Future payments

1. IHTM14871

   Future payments: Introduction
2. IHTM14872

   Future payments: Calculating the chargeable portion
3. IHTM14873

   Future payments: Exemptions
4. IHTM14874

   Future payments: Payments outstanding at death

Dating of dispositions

1. IHTM14881

   Dating of dispositions: Introduction
2. IHTM14882

   Dating of dispositions: Gifts by cheque
3. IHTM14883

   Dating of dispositions: Dispositions affecting land
4. IHTM14884

   Dating of dispositions: Chattels and corporeal moveables
5. IHTM14885

   Dating of dispositions: Choses in action and incorporeal moveables

Investigation issues

1. IHTM14890

   Investigation issues: Voidable transfers
2. IHTM14900

   Investigation issues: Donatio Mortis Causa (DMC)