The Inheritance Tax Act 1984, s. 196 applies where the appropriate person, acting in the same capacity, has carried out one of the following transactions:

(1)a ‘collusive’ sale within s. 191(3) (see ¶628-800 above); or

(2)within the period of three years after death, an exchange, whether with or without any equalising payment, of an interest in land comprised in the estate at death;

and the sale price, or in the case of an exchange the market value at the date of the exchange, of the interest exceeds the value on death.

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