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HMRC internal manual

Inheritance Tax Manual

Liabilities: investigating form IHT419: when property derived from the deceased can be disregarded for FA86/S103 purposes?

The definition of property derived from the deceased (IHTM28367) is wide-ranging. But, an earlier disposition should be ignored if

  • it was not a transfer of value (IHTM04151), and
  • it is shown that it was not part of associated operations (IHTM09152) which contained any element of direct or indirect bounty, FA86/S103 (4).

An exempt transfer should be treated as a transfer of value for the purposes of this legislation.