Special rules apply in respect of transfers of value made on or after 18 March 1986, where part of the value transferred is attributable to business or agricultural property qualifying for relief under IHTA 1984, s. 104 or 116 (see ¶664-000 and ¶658-000 respectively). To attribute the value transferred (as reduced by relief) to specific gifts and gifts of residue, the rules in s. 39A must be applied.

Under s. 39A(1)–(4), (6), value is attributed as follows:

The value of specific gifts of business or agricultural property is taken to be their reduced value after relief.

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