A transfer of value by an individual who is beneficially entitled to shares in a company in favour of trustees of a settlement meeting the description in IHTA 1984, s. 86 is an exempt transfer (s. 28). There are a number of conditions which must be fulfilled. The exemption is discussed in ¶646-600.
Disposition by a close company
A more common scenario is a disposition to trustees of a settlement covered by IHTA 1984, s. 86 by a close company (see ¶364-750). This is not a transfer of value provided the following two conditions are satisfied (s. 13):