{#}Chargeable and Exempt Transfers

Hold-over relief under TCGA92/S260 can be claimed where the disposal amounts to a chargeable transfer within the meaning of IHTA84, common examples of which being gifts to most settlements (see IHTM04027 for further detail). Relief is available in this instance even if no Inheritance Tax is actually payable, for instance if the transfer of value is covered by the Annual Exemption or a Nil-Rate Band. This is also relevant for disposals like that in Melville v IRC [2001] BTC 8039 where there is a significant capital gain but the value of the transfer for Inheritance Tax purposes is low – relief will still be available in these circumstances.

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