‘On the death of any person tax shall be charged as if, immediately before his death, he had made a transfer of value and the value transferred by it had been equal to the value of his estate immediately before his death.’
This is qualified in certain respects by the legislation which follows.
Death is not stated to be a transfer of value, or a disposition. Instead, tax is charged ‘as if’ a transfer of value had been made immediately before death. For the reasons behind this approach, and the practical implications of it, see ¶601-300ff.