IHTM14853 - Lifetime transfers: transfers by close companies: exemptions

Any transfer by a close company is a deemed transfer (IHTM04061) for Inheritance Tax purposes and is not a potentially exempt transfer (IHTM04057), but

• the annual exemption (IHTM14141) is available as the restriction in IHTA84/S19(5) to deemed transfers of value does not extend to transfers under IHTA84/S95(5).

as is

• spouse or civil partner exemption (IHTM11031) to the extent that the estate of the spouse or civil partner of a participator is increased.

The exemptions for

• small gifts (IHTM14180),
• normal expenditure out of income (IHTM14231), and
• gifts in consideration of marriage or civil partnership (IHTM14191)

are not available since they cannot apply to deemed transfers.