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HMRC internal manual

Inheritance Tax Manual

Ten year anniversary: the deemed transfer for rate

IHTA84/S66 provides that the charge is as if there is a hypothetical transfer at the ten year anniversary (TYA) and the values deemed to be transferred are the values of

1) Property on which tax is chargeable now

  • Relevant property in the settlement, valued on the day before the TYA (IHTM42161)
  • Value net of AR/BR


2) Other aggregate property (Only for settlements made after 27 March 1974):

  • Any property in the settlement which is not relevant property, valued at the date it was put into the settlement. This is known as the historic value.

(This reflects any part of the fund that might be an interest in possession or have A&M powers, for example.)


  • Any related trusts valued at the time they were set up. (IHTM42230). Also the historic value.

The overall total is the assumed chargeable transfer for calculating the rate of tax.