A transfer of value is any disposition made by the transferor as a result of which the value of his estate immediately after the disposition is less than it would be but for the disposition. The amount by which it is less is the value transferred by the transfer (the loss to the estate rule) – if the transferor pays any IHT due that is also a reduction in the estate and a grossing up process is necessary (see ¶16125). The reduction in the donor’s estate may not match the increase in the donee’s estate.


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