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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: future payments: introduction

IHTA84/S262 provides the machinery for charging tax in cases where a disposition is made

  • for partial consideration and
  • the transferor satisfies their part of the bargain wholly or partly more than a year after it is made.

Each payment made by the transferor, or each transfer of assets by him, is treated as a separate disposition and is taxed accordingly. But the value transferred will not necessarily be equal to the amount paid or to the value of the asset transferred. The example at IHTM14872 shows how the chargeable part of each disposition is established.