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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: associated operations: sale without immediate payment of the purchase price

In this situation, property (typically a house) is sold with the purchase price being treated as a loan. Subsequently, the loan is released in stages (normally in order to utilise the annual exemptions). Also see IHTM14152. You need to

  • consider whether the sale price represents the full open market value of the property at the date of the sale,
  • consider whether the purported releases are legally effective (IHTM19100), and
  • establish by whom and on what basis the property was occupied between the sale and the death (so that the application of the Gift With Reservation (IHTM14301) provisions can be considered).
  • attribute to the participators in a close company a transfer of value made by the company and
  • treat alterations in capital or rights as a disposition made by the participators.