SVM108057 - Inheritance Tax: Risk Assessment on a chargeable lifetime transfer

IHTM4067 gives a full list of situations where transfers that are chargeable when made.

As with other IHT referrals of unquoted shares, concentrate on the availability of Business Relief. If the relief is not available and a valuation is required, the chargeable value of the transfer is calculated on a loss to the estate basis. IHTM14533 gives an example of how this works on transfers that are chargeable when made. The transfer is only aggregated with other chargeable when made transfers, not Potentially Exempt Transfers (PETs).

The rate of tax on these transfers is half the death rate (20%).

If a valuation is required you may find information in the course of your research that had not been supplied to the IHT caseworker, for example other transfers of shares listed on the company Annual Return. If other information does come to light you should liaise with the IHT caseworker about how to proceed.

Additional Guidance: SVM150000