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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Pensions: IHT exclusions: contributions to a pension scheme

Generally, when a person makes a contribution to a pension scheme, they do not make a transfer of value as the pension rights they acquire by making the contribution are within their estate. But, there are exceptions - IHTM17042 and IHTM17043 describe specific situations where contributions can be transfers of value.

There is also a specific exclusion in IHTA1984/S12(2) where a disposition is made by an employer. The disposition is not a transfer of value if it is:

  • a contribution under a registered pension scheme (IHTM17021),
  • a qualifying non-UK pension scheme (IHTM17025) or
  • a section 615(3) scheme (IHTM17026) in respect of an employee of the person making the disposition.