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.