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HMRC internal manual

Inheritance Tax Manual

Dispositions allowable for income tax or conferring retirement benefits: outline of IHTA84/S12

IHTA84/S12 provides that two types of disposition (IHTM04023) are not transfers of value (IHTM04024). They are:

  • those allowable in computing a person’s profits for income tax purposes, (IHTM04172)
  • certain contributions to retirement benefits. (IHTM04193)

If only part of a disposition satisfies the requirements of IHTA84/S12, you should treat the part that does and the part that does not as separate dispositions, IHTA84/S12 (5).

If the parties claim, or the information before you suggests, that a disposition is the provision of retirement benefits, you should seek advice from Technical.