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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Exclusions from exemption: postponed gifts

A gift to a charity (IHTM11112) is not exempt if it takes effect on the termination, after the transfer of value, (IHTM04024) of any interest or period. We interpret the term ‘takes effect’ to mean ‘takes effect in possession’. (IHTA84/S23 (2) (a))



Ashley dies.

By Will Ashley leaves the residue of his estate to Leonora for life, and then to a charity when Leonora dies.

IHTA84/S23 (1) does not provide exemption on Ashley’s death (though it may on Leonora’s).