IHTM04118 - Heritage property: double charges

The same event may be a chargeable event for

• more than one conditionally exempt transfer, or
• a conditionally exempt transfer and exemption on a death before 7 April 1976.

Any such case should be referred to Heritage.

Example

Greta dies in 1997 and bequeaths a mansion house and surrounding land to her son, Guido. It is a conditionally exempt transfer of the house and land. In 2003, Guido settles both properties on discretionary trusts. Again it is a conditionally exempt transfer. In 2010, the trustees sell both the house and land by auction. The sale is a chargeable event in respect of both conditionally exempt transfers.