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Answer to Example 2
The gift on 1 October 2010 to her son is a PET. This was not chargeable when made nor will it be
chargeable on death as Dee survived for the required 7 years. The transfer is therefore exempt but
will be deemed to have used the Annual Exemptions for 10/11 and 09/10.
The gift on 1 June 2011 is a CLT and was chargeable when made during lifetime, but not again on
death as again Dee survived for 7 years.
The gift on 1 September 2017 is a PET and will be chargeable on death as Dee died within the next 7
years.
Step 1
Compute the Chargeable Transfers: Lifetime tax
AE 10/11 will have been applied to the 1 October 2010 PET despite it never becoming chargeable.
As the donor, Dee, paid the IHT, the transfer is a net transfer and therefore the excess over the nil
rate band is taxed at 25%
Step 2
Lifetime Transfers Chargeable on Death: Additional tax
The PET on 1 September 2017 is now chargeable to IHT as the gift was made within 7 years of the
date of death.
When calculating the tax it is necessary to look back seven years from September 17 to see if any
gifts will use up the NRB. The CLT from June 2011 does use up the nil rate band.
1/6/11
1/9/17
CLT
PET
Transfer of value
336,000
296,000
Less: Exemptions
AE 11/12
(3,000)
AE 17/18
(3,000)
AE 16/17
(3,000)
Chargeable
Transfer
333,000
290,000
£
Gross
Transfers
IHT
1/6/11
CLT
333,000
335,000
2,000
325,000 @ nil
= nil
8,000 @ 25% = 2,000
Gross
Transfers
IHT
1/9/2017
PET
290,000
116,000
No available nil rate band
290,000
285
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