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HMRC internal manual

Inheritance Tax Manual

Dispositions that are not transfers of value: introduction

There are a number of provisions in IHTA84/S10 to IHTA84/S17 which provide that the disposition (IHTM04023) concerned is not a transfer of value.(IHTM04024) This does not make the transfers into exempt transfers (IHTM04026) but a disposition that satisfies the requirements cannot come within IHTA84/S3 (1) and so cannot be a chargeable transfer.(IHTM04027) However, as these provisions apply to an actual disposition, it is considered that they cannot apply to a charge which is based on a deemed transfer, (IHTM04025) unless the legislation specifically applies the provisions to the deemed transfer concerned. This is because the legislation brings the charge into existence at a point after the provisions can apply. (IHTM04022) An example of where the legislation specifically applies these provisions is the application of IHTA84/S10, IHTA84/S11 and IHTA84/S16 to lifetime dispositions of settled property (IHTM04083).