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Chapter 24
INHERITANCE TAX
1. Introduction
To be within the scope of Inheritance tax (IHT) there must be a transfer of value of chargeable
property by a chargeable person.
Transfer of Value
IHT is a cumulative donor-based tax. For it to arise, an individual must make a transfer of value i.e. a
gift, which results in the reduction of the donor's estate. The loss to the donor principle is known as
diminution and includes:
๏
lifetime
transfers
๏
the wealth a person leaves when they die (their estate)
The amount of tax that may be payable on that gift/transfer of value is based on the cumulative
amount of transfers made by the donor over a 7-year period.
Illustration 1
A owns 60% of the shares in A Ltd. A Ltd has 100,000 £1 ordinary shares in issue.
Share valuations have been agreed with HMRC as follows:
20%
£10
per share
40%
£15 per share
60%
£25 per share
80%
£40 per share
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