This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: what is an individual

For a transfer of value (IHTM04024) to be a potentially exempt transfer, (IHTM04057) the transfer has to be by an individual, that is, a human being, IHTA84/S3A (1). Contrast this with the general requirement in IHTA84/S3 (1) that a transfer of value must be made by a person, which has a wider meaning including a corporation or company.

In applying this concept to a deemed transfer of value (IHTM04025) under IHTA84/S52, the person whose beneficial interest in possession (IHTM16062) in the settled property has come to an end is the individual who made the transfer for the purposes of IHTA84/S3A (1)(a).