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HMRC internal manual

Inheritance Tax Manual

Successive transfers: Limitations on relief

IHTA84/S121 (2) refers back to the replacement provisions (IHTM24132) in IHTA84/S121 (1)(c). It provides that, except where the replacement concerned resulted from the formation, alteration or dissolution of a partnership, the agricultural relief shall not exceed what it would have been had the replacement(s) not been made. Your approach to S121(2) should be similar to that to replacement property (IHTM24112) generally.

Similarly, if the earlier transfer arose from a disposition which was part bounty and part for consideration, for example, a sale at less than the full value, IHTA84/S121 (3) provides that the relief on the second transfer is restricted to the proportion of the value corresponding to that which the element of gift bore to the total value involved in the first transferor’s disposition.