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IHTM14624 | Lifetime transfers: specific lifetime reliefs: fall in value relief: conditions for relief

From HM Revenue & Customs · Inheritance Tax Manual

All the following conditions must be satisfied before you can allow any relief

  • The value transferred by the failed potentially exempt transfer () or chargeable transfer must be wholly or partly attributable to property which either

    • remains the property of the transferee (or of the spouse or civil partner () of the transferee) at the date of death, or

    • has been sold by the transferee (or spouse or civil partner of the transferee) by an earlier qualifying sale ().

  • The market value () of the transferred property at the time of the transfer must exceed its market value at the date of death or sale.

  • A claim in writing must be made by a person liable to pay the tax, or additional tax (), within 4 years of the date of the donor’s death, IHTA/S131(2ZA).