(1) Transfers on death

The Inheritance Tax Act 1984, s. 4(1) provides that the value transferred by the hypothetical transfer of value immediately before death is ‘equal to the value of [the deceased's] estate immediately before his death’.

In the case of death, then, a valuation of the whole of the deceased's estate immediately before death is required. Detailed rules defining a person's ‘estate’ are to be found in IHTA 1984, s. 5, and the meaning of ‘estate’ is considered further at ¶624-250.

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