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Finance Act 1986
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35In section 239 (certificates of discharge) after subsection (2) there shall be inserted the following subsection—
“(2A)An application under subsection (1) or (2) above with respect to tax which is or may become chargeable on the value transferred by a potentially exempt transfer may not be made before the expiration of two years from the death of the transferor (except where the Board think fit to entertain the application at an earlier time after the death).”
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