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Home / Simons-Taxes /IHT, trusts and estates /Part I3 Lifetime transfers /Division I3.7 Pre-owned assets tax (POAT) /POAT—existing arrangements / I3.752 POAT—reversionary lease schemes
Commentary

I3.752 POAT—reversionary lease schemes

IHT, trusts and estates

Reversionary lease schemes, like Ingram schemes, created a leasehold from an existing freehold. A reversionary lease scheme would involve such a leasehold interest being created in the same way, but it would take effect after a set period, usually less than 21 years. The lease would be gifted away and its value would be a PET in the normal way. The donor could continue to occupy the property until the deferred period with no IHT consequences.

Such arrangements do not fall within FA 1986, s 102A unless the freehold has been acquired within seven years before the grant of the lease (see I3.408,

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