ABSTRACT
The IHTA 1984 charges inheritance tax on the value transferred by chargeable transfers (s 1). Chargeable transfers are defined as transfers of value made by individuals, which are not exempt transfers (s 2(1)), and transfers of value are dispositions which result in the reduction in the value of the disponor’s estate (s 3(1)). In this question, the ‘donations’ made by Emily would be dispositions within the meaning of the IHTA. There is no doubt that these dispositions result in the value of her estate being diminished. Consequently, one would conclude that she has made a transfer of value. Two questions then arise – the value which was actually was transferred, and, whether this transfer will attract a charge to inheritance tax.
