The measure of liability to inheritance tax, including tax on lifetime gifts, is the ‘value transferred’ by a transfer, i.e. the amount by which the transferor’s estate is less than it otherwise would have been (IHTA 1984, s. 3(1)).

In England, a partnership has no legal persona of its own, and so is incapable of making a transfer of value. Any transfer of partnership property will thus be a transfer of value by such of the individual partners who are beneficially entitled to shares of the partnership assets.

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