602-500 Value transferred by an event treated as if it were a transfer of value
(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.