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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: transfers that cannot be potentially exempt transfers

There are two transfers of value that are specifically prevented from being potentially exempt transfers (IHTM04057). These are

  • the deemed disposition on an alteration in the capital or share rights of close companies, (IHTM04069) IHTA84/S98 (3), and
  • a transfer to the extent to which the property transferred consists of woodlands subject to a deferred Estate Duty charge, (IHTM04062) FA86/SCH19/PARA46.