IHTM04191 | Dispositions allowable for income tax or conferring retirement benefits: outline of IHTA84/S12
From HM Revenue & Customs · Inheritance Tax Manual
IHTA84/S12 provides that two types of disposition (IHTM04023) are not transfers of value (IHTM04024). They are:
If only part of a disposition satisfies the requirements of IHTA84/S12, you should treat the part that does and the part that does not as separate dispositions, IHTA84/S12 (5).
If the parties claim, or the information before you suggests, that a disposition is the provision of retirement benefits, you should seek advice from Technical.