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Home / Simons-Taxes /IHT, trusts and estates /Part I5 Settled property /Division I5.3 Settlements within the relevant property regime /Exit charges before first anniversary—calculating the charge / I5.314 Appropriate fraction for exit charges
Commentary

I5.314 Appropriate fraction for exit charges

IHT, trusts and estates

The effective rate of charge is then adjusted to reflect the period during which the property subject to the exit charge has been relevant property (I5.303) since the settlement commenced. This 'appropriate fraction' may be different for different parts of the property, and because the property or some of it may not have been relevant property all the time since the settlement commenced.

The appropriate fraction is calculated as follows:

  1. Ìý

    (1)ÌýÌýÌýÌý Calculate the number of complete successive quarters in the period beginning with the day on which the settlement commenced and ending with the day before the occasion of charge1.

  2. Ìý

    (2)ÌýÌýÌýÌý Consider whether the whole or any part of the amount on which the exit tax is charged is attributable to property which was not relevant property, or was not comprised in the

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