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On 15 March 2006 the first appellant made two gratuitous dispositions of land in favour of himself and the second appellant as trustees of an accumulation and maintenance trust.
The dispositions were delivered to the trustees on that date but one was recorded in the Register of Sasines in October 2006 and the other in November 2006.
HMRC said that the transfers were not potentially exempt because they were recorded after 22 March 2006 and therefore the first appellant was liable for the inheritance tax on them.
Finance Act 2006 amended IHTA 1984 to the effect that a gift into an accumulation and maintenance trust was a potentially exempt transfer only if made before 22 March 2006.
The taxpayers appealed saying that the gifts had been effected by the delivery of the dispositions and were thus potentially exempt.
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