The Inheritance Tax Act 1984, s. 141 gives relief from tax in certain cases where a charge arises in respect of property which has been subject to another charge within the last five years. Since 1981, relief has been given to settled property in the same manner as to property owned absolutely. The Inheritance Tax Act 1984, s. 141(2), which applies the relief to settled property in which an interest in possession subsists, lays down the following conditions:

(1)the value transferred by the second transfer is determined by reference to the value of settled property to which the transferor is entitled to an interest in possession;

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