transfer of value
Inheritance tax is charged when there is a “transfer of value” that is not exempted by any statutory provision. A transfer of value is any disposition made by the transferor as a result of which the value of his estate immediately after the disposition is less than it would be but for the disposition (Inheritance Tax Act 1984 s 3(2)). Statute declares the reduction in the estate not to be a transfer of value if it can be shown that the transfer was not intended to confer any gratuitous benefit and occurred as part of a commercial transaction. A disposition for maintenance of the family (which is very restrictively defined) is also declared by statute not to be a transfer of value. |