Where a person who is beneficially entitled (IHTM04031) to an interest in possession (IIP) (IHTM16000) in settled property ‘disposes’ of their interest, IHTA84/S51 (1) applies. The disposal does not rank as an actual transfer of value (IHTM04024) but is treated as ‘the coming to an end of their interest’. Tax is charged in accordance with IHTA84/S52 (1): this means that the disposal is regarded as a deemed transfer of value (IHTM04025) and the lifetime exemptions (IHTM14131)are excluded.

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