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Home / Simons-Taxes /IHT, trusts and estates /Part I3 Lifetime transfers /Division I3.2 Value transferred by a transfer of value /Restrictions on deduction of liabilities—anti-avoidance / I3.241 Liabilities attributable to financing relievable property
Commentary

I3.241 Liabilities attributable to financing relievable property

IHT, trusts and estates

I3.241 Liabilities attributable to financing relievable property

In relation to transfers of value made or treated as made on or after 17 July 2013, IHTA 1984, s 162B imposes restrictions on the deduction of any liability incurred on or after 6 April 2013 to finance relievable property. Relievable property in this context means relevant business property entitled to BPR under IHTA 1984, s 1041, agricultural property entitled to APR under IHTA 1984, s 1162, or woodlands entitled to deferment of IHT charge under IHTA 1984, s 1253.

For further information on BPR, APR and woodlands relief see I7.101, I7.302 and I7.402.

IHTA 1984, s 162B makes essentially the same provision in relation to all three categories of relievable property. Section 162B applies if there is a transfer of value made, or treated as made, on or after 17 July 2013, where the following conditions are met: the value transferred is wholly or partly attributable to relievable property, and the transferor at the time of the transfer has a liability

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