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A gratuitous intent?
KEY POINTS
- The Court of Appeal overturned the decisions of the lower tribunals in HMRC v Parry.
- The taxpayer transferred a section 32 pension plan to a personal pension scheme to prevent her ex-husband benefiting on her death.
- Because she was in ill-health HMRC argued that an inheritance tax transfer of value arose.
- A disposition is not a transfer of value if no gratuitous benefit was intended (IHTA 1984 s 10).
- Associated operations must be taken into...
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