I3.157 Exclusions To Dispositions For IHT―Waiver Of Remuneration

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Commentary

IHT, trusts and estates

A waiver or repayment of remuneration is not a transfer of value if two conditions are fulfilled. These are¹:

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(a)�� that the remuneration would be earnings, or would be treated as earnings and would constitute employment income if it were not waived or repaid, and
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(b)�� that the remuneration would, if not waived or repaid, be deductible from the profits or gains of the employer for income or corporation

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I7.333A Companies and replacement APR property

I9.421 Situs of simple contract debts for IHT

I4.142A Liabilities which are not discharged out of the estate

B3.340A Hire purchase of plant and machinery and similar contracts

B4.130 Summary of OECD guidelines on arm's length principle

B2.218 Surplus business accommodation

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I3.157 Exclusions to dispositions for IHT―waiver of remuneration

IHT, trusts and estates

I7.333A Companies and replacement APR property

I9.421 Situs of simple contract debts for IHT

I4.142A Liabilities which are not discharged out of the estate

B3.340A Hire purchase of plant and machinery and similar contracts

B4.130 Summary of OECD guidelines on arm's length principle

B2.218 Surplus business accommodation

C3.1814A CGT exempt assets—qualifying corporate bonds (QCB)

E4.11120 Additional annual returns by employers—overview

E8.810 Application for a National Insurance number

A1.810 Limitation

B5.812A Particular charitable bodies

E5.406 Employees of European Union delegations—tax exemptions

I5.226 Disposals of QIIPs for consideration

I8.335 Valuation on death of partner in service

C2.1168 Property rich collective investment vehicles—ceasing to meet the exemption election requirements

C3.305 Rollover relief—time limit for acquisition of replacement assets

D3.410 Benefits provided by close companies to participators

D1.1061 Substantial shareholding exemption—interaction with other reliefs

I11.215 IHT accounts—excepted settlements

D6.330 Special situations involving a transfer of trade with common ownership—business of leasing plant or machinery

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I3.157 Exclusions to dispositions for IHT―waiver of remuneration

IHT, trusts and estates

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