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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: what is an immediately chargeable transfer?

Any lifetime transfer that does not qualify as a PET (IHTM04057) will be immediately chargeable to IHT under IHTA84/S3 (1). Two transfers that do not qualify are a

  • transfer into a discretionary trust, because the gift is not to an individual or one of the specified trusts, see IHTM04058 (IHTM04058), and
  • transfer to a company, see example 2 at IHTM04060There may also be an alternative charge on the property transferred under the GWR rules. (


There are four other transfers of value (IHTM04024) that are specifically prevented from being PETs. These are a

  • transfer by a close company, (IHTM04068) IHTA84/S94 (1),
  • the deemed disposition on the alteration in the capital or share rights (IHTM04069) of close companies, IHTA/S98 (3),
  • the release of a life interest (IHTM04063) between 18 March 1986 and 16 March 1987, and
  • the transfer of woodlands (IHTM04062) subject to an outstanding Estate Duty charge, which only qualifies for partial PET treatment.