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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
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Lifetime transfers: schemes to exploit annual exemption: transfer of a sum of money

The subject matter of the transfer is a sum of money which is in effect a floating charge on the property. Typically the deed shows that the property is held on a trust for sale and the proceeds are to be held as to £3,000 for the donee and the balance for the deceased.

  • In this situation all of the subsequent increase in the value of the property accrues for the deceased’s benefit. The death estate must include the open market value of the property less £3,000.
  • On the initial transfer and any subsequent transfers the value transferred is equal to the sum of money transferred.

Refer any Scottish deed attempting to transfer part of a property in this way to Technical.