Inheritance tax is chargeable on transfers of value and on events treated as if a transfer of value had been made. In the context of lifetime transfers one is normally concerned with actual transfers of value defined in IHTA 1984, s. 3(1) as:

‘… a disposition made by a person (the transferor) as a result of which the value of his estate immediately after the disposition is less than it would be but for the disposition.’

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