The normal rule that earlier transfers attract the exemption is displaced in respect of transfers made on the same day. Instead, the exemption available is attributed to the transfers in proportion to their values (IHTA 1984, s. 19(3)(b)).

Example 1

John, who had used up his 2020-21 annual exemption, made the following gifts in 2011-22:

1 June 2021

£4,000 to Kate

1 June 2021

£2,000 to Linda

1 December 2021

£1,000 to Mary

J dies in May 2022.

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