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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: deemed potentially exempt transfers

The legislation also provides that the following transfers shall be treated as if they were PETs. (IHTM04057) This means that the individual (IHTM04053) has made a PET and not simply a transfer of value so the conditions to qualify as a PET do not have to be considered. The transfers are

  • the lifetime cessation of a reservation in GWR property, (IHTM04072) FA86/S102 (4), and
  • discharge or reduction of a debt subject to abatement FA86/S103 (5). Because these transfers are deemed to be PETs, and a PET is transfer of value (

IHTM04024) that would, apart from IHTA84/S3A be a chargeable transfer, (IHTM04027) they join the charging structure as chargeable transfers. This means that no exemptions (IHTM11000) may be deducted.

The same would apply for reliefs such as agricultural relief (IHTM24000) and business relief (IHTM26000). However, these reliefs are specifically available against the deemed PET that arises on the cessation of reservation(FA86/SCH20/PARA8). However, there is no corresponding provision for the reduction of a debt subject to abatement. Any transfer made in this way is not entitled to any exemptions or reliefs.