Inheritance Tax Act 1984

10 Dispositions not intended to confer gratuitous benefit.U.K.

(1)A disposition is not a transfer of value if it is shown that it was not intented, and was not made in a transaction intended, to confer any gratuitous benefit on any person and either—

(a)that it was made in a transaction at arm’s length between persons not connected with each other, or

(b)that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.

(2)Subsection (1) above shall not apply to a sale of [F1unquoted shares or unquoted debentures] unless it is shown that the sale was at a price freely negotiated at the time of the sale or at a price such as might be expected to have been freely negotiated at the time of the sale.

(3)In this section—

  • disposition” includes anything treated as a disposition by virtue of section 3(3) above;

  • transaction” includes a series of transactions and any associated operations.

Textual Amendments

F1Finance Act 1987 Sch. 8, para. 1,with effect from 17March 1987.Originally

“shares or debentures not quoted on a recognised stock exchange”.