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Home / Simons-Taxes /IHT, trusts and estates /Part I7 Special reliefs /Division I7.1 Business property relief (BPR) /Business property relief on lifetime transfers within seven years of death (BPR 'clawback') / I7.195 BPR clawback—example of the different effects of a PET and CLT on the cumulative total
Commentary

I7.195 BPR clawback—example of the different effects of a PET and CLT on the cumulative total

IHT, trusts and estates

Example 1—clawback on a PET and effect on cumulative total

A makes a potentially exempt transfer of a 10% holding of unquoted shares in a trading company on 8 August 2018 to B. She had made a chargeable transfer of £200,000 in 2015, within the seven years before this transfer. No transferable nil rate band is available to her.

In January 2020 B gave the 10% holding to C.

A died on 5 February 2021.

The diminution in value of A's estate by virtue of the transfer of the 10% holding was

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