A disposition in favour of a dependent relative is not a transfer of value if it constitutes reasonable provision for the relative's care and maintenance1 (contrast with the position of the spouse and children, for which see I3.151, where the provision is for maintenance only). The word 'reasonable' is not found elsewhere in the section. In HMRC's view 'care' suggests the provision of services, whether privately or in an institution, and 'reasonable' suggests an amount that is reasonably necessary for the purpose of providing care and maintenance, but no more, taking account of the financial and other circumstances of the transferor and their relative, and the relative's level of incapacity or infirmity2.
Meaning of 'relative'
The exemption covers dispositions in favour of (i) a relative of the disponor (or
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