IHTM25523 - AR/BR 100% relief allowance: individuals – apportionment – more than one chargeable transfer
If only one transfer of relievable property qualifying for 100% AR/BR is made on a particular day, the available allowance will be £2.5m less the value of any other transfers of relievable property qualifying for 100% AR/BR made within the 7 years immediately preceding the date of this transfer, IHTA84/S124D (2).
Where there is more than one transfer on the same day and the total value of the transfers is less than the amount of the 100% allowance available, then each transfer will be fully relieved at 100%.
But where more than one transfer of relievable property is made on the same day and the 100% relief allowance applies to each of them, and the total relief is in excess of the allowance available then you will need to apportion the allowance between each qualifying transfer.
Example 1
Angela transfers agricultural land valued at £750,000 to a discretionary trust for the benefit of her son Anthony on 1 June 2026. On the same day she transfers unquoted shares valued at £500,000 to a separate trust for the benefit of her daughter Alex. She has not used any of her £2.5m 100% AR/BR allowance before this date. As the total value of the relievable transfers is £1.25m, both transfers qualify for 100% AR/BR in full, and £1.25m of Angela’s allowance is available to use against later transfers.
But where the value of the relievable transfers exceeds the available amount of 100% AR/BR allowance, IHTA84/S124D (4) sets out how the apportionment of the allowance applies. It refers to a ‘conditionally relievable transfer’ which is defined at IHTA84/S124D (10)(a) as a chargeable transfer made by the transferor not on death and which would qualify for 100% AR/BR. If there is more than one conditionally relievable transfer on the same day and the potentially relievable amount of those transfers (defined as the value that would qualify for AR/BR if the relief was unlimited, IHTA84/S124D (10)(b)) exceeds the value of the available allowance, you must calculate the allowance available against each individual transferred asset using the formula at IHTA84/S124D (5):
(The potentially relievable value of the transfer ÷ The total of the potentially relievable values of the transfers made on that day) x The amount of the 100% AR/BR allowance available against all the transfers made on that day)
Example 2
Stephen makes three transfers of unquoted shares on 1 November 2026. He transfers shares valued at £3m to Paul, £2m to Susan and £1m to Clive, all qualifying for 100% BR. Stephen then dies on 1 December 2026.
As the total relievable value of the transfers amounts to £6m, exceeding Stephen’s 100% AR/BR allowance of £2.5m, you must apply the calculation in IHTA84/S124D (5) to each chargeable transfer to calculate the amount of 100% BR applicable to each, as follows:
Paul: (£3m ÷ £6m) x £2.5m = £1.25m 100% BR available. Balance of £1,750,000 qualifies for 50% BR leaving £875,000 chargeable.
Susan: (£2m ÷ £6m) x £2.5m = £833,333 100% BR available. Balance of £1,166,667 qualifies for 50% BR leaving £583,333 chargeable.
Clive: (£1m ÷ £6m) x £2.5m = £416,667 100% BR available. Balance of £583,333 qualifies for 50% BR leaving £291,667 chargeable.