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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: schemes to exploit annual exemption: transfer of share equal to a sum of money

The subject matter of the transfer is a share of the property equal in value to a sum of money. For example, the deed states that such share of the property as is equal in value to £3,000 is to be held for the donee and the balance for the deceased. If for example the property is worth £200,000 then a share of the property equal in value to £3,000 is 98.5%.

Where the property was the residence, and was held in the deceased’s sole name before the transfer, you need to calculate the loss to the estate. You must ask the Valuation Office (IHTM23002) to value both

  • the entirety with vacant possession as at the date of transfer, and
  • the retained share as at the date of transfer

and then to value

  • whatever is then the retained share in the death estate as at the date of death.

Subsequent transfers

After the initial transfer you can accept (without reference to the Valuation Office) that the value transferred on any subsequent transfer was equal to the value of the sum of money in the relevant deed.