The rule that transfers are added to a person's cumulative total in the order in which they are made does not apply to lifetime transfers made on the same day. Instead, IHTA 1984, s. 266(2) provides that the rate chargeable on the values transferred by chargeable gifts made on the same day is to be the effective rate which would have been chargeable on a single gift of the total value. The gifts must therefore be added together, and tax on the total calculated.
A, who had a gross cumulative total of £295,000, made the following chargeable gifts on 1 March 2011. A died on 1 January 2014.
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