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July 17, 2023
17
Jul

If an individual who owns 100% of the shares in a company gives shares to the individual’s children but continues to use a property held by the company, would there be a gift with reservation of benefit for inheritance tax purposes?

17th July 2023
We have assumed that: The individual is domiciled in the UK and the shares in the company are UK situs property, and The individual does not pay full market rent for the occupation of the property The reservation of benefit treatment of a disposition for inheritance tax (IHT) purposes arises, by virtue of section 102(3) of the...