Where settled property is subject to a qualifying interest in possession (QIIP), the person entitled to the interest in possession (often called the 'life tenant') is treated as the owner of that property1.
The termination of all or a part of his interest in possession during his life is treated for the purposes of IHTA 1984, including APR, as a transfer of value by him of the settled property subject to the interest2 — see I5.221. On his death while still entitled to the interest, the settled property forms part of the transfer of value he is treated as having made immediately before his death3 (see I5.241).
There are also specific rules that the voting rights of shares
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Web page updated on 17 Mar 2025 17:08