IHTM14853 | Lifetime transfers: transfers by close companies: exemptions

From HM Revenue & Customs · Inheritance Tax Manual

Any transfer by a close company is a deemed transfer () for Inheritance Tax purposes and is not a potentially exempt transfer (), but

  • the annual exemption () is available as the restriction in to deemed transfers of value does not extend to transfers under IHTA84/S95(5).

as is

  • spouse or civil partner exemption () to the extent that the estate of the spouse or civil partner of a participator is increased.

The exemptions for

  • small gifts (),

  • normal expenditure out of income (), and

  • gifts in consideration of marriage or civil partnership ()

are not available since they cannot apply to deemed transfers.