IHTM04061 | Lifetime transfers: transfers that cannot be potentially exempt transfers
From HM Revenue & Customs · Inheritance Tax Manual
There are two transfers of value that are specifically prevented from being potentially exempt transfers (). These are
the deemed disposition on an alteration in the capital or share rights of close companies, () , and
a transfer to the extent to which the property transferred consists of woodlands subject to a deferred Estate Duty charge, () .