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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: what is a person?

The disposition (IHTM04023) has to be by ‘a person’. In law, this includes a corporation or company as well as a natural person. However in relation to the charging provisions, this wide meaning is effectively cut down by the definition of a chargeable transfer. (IHTM04027) To be chargeable, a transfer of value (IHTM04024) has to be either

  • by an individual, (IHTM04053) that is a human being, or
  • by a close company (IHTM04068) and be treated under IHTA84/S94 to IHTA84/S102 as a transfer of value by an individual.