IHTM14624 - Lifetime transfers: specific lifetime reliefs: fall in value relief: conditions for relief
All the following conditions must be satisfied before you can allow any relief
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The value transferred by the failed potentially exempt transfer (IHTM04057) or chargeable transfer must be wholly or partly attributable to property which either
- The market value (IHTM14626) of the transferred property at the time of the transfer must exceed its market value at the date of death or sale.
- A claim in writing must be made by a person liable to pay the tax, or additional tax (IHTM14571), within 4 years of the date of the donor’s death, IHTA/S131(2ZA).