As explained in I6.111, the effect of IHTA 1984, s 98 is to treat the participators in a close company as having made a disposition at the time of any alteration in the shares or securities of the company. That is so whether the participators hold their shares or securities beneficially or as trustees.
Thus, if IHTA 1984, s 98 deems a disposition to have been made by the trustees of a settlement in which no qualifying interest in possession (QIIP) subsists and (as a result of that deemed disposition) the value of the settled property is less than it would have been, but for that disposition, a charge to IHT arises under the depreciatory transaction provisions of IHTA 1984, s 65(1)(b) (see I5.307).
Where a QIIP does subsist
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