A waiver of a dividend on shares of a company within 12 months before any right to the dividend has accrued is not a transfer of value (IHTA 1984, s. 15). It will be noted that s. 15 differs from s. 14 (waivers of remuneration) in requiring the waiver to be exercised before a right to the dividend accrues. It only applies to dividends on shares, and not to any other form of receipt, such as debenture interest.

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