IHTM04066 - Lifetime transfers: what is the value transferred by a potentially exempt transfer?
There are two ways (IHTM04058) in which a transfer may be a potentially exempt transfer (PET) (IHTM04057).
Where property becomes comprised in the estate (IHTM04029) of another individual or becomes qualifying settled property, you should, as a general rule, calculate the value transferred by a PET by reference to the loss to the transferor바카라 사이트™s estate (IHTM04054). However, there can be no grossing up (IHTM14593) because the transferor is not liable for the tax on a PET and the value for tax, but not the value for cumulation, may be reduced if the value of the property falls after the gift. (IHTM14621)
Where a transfer qualifies as a PET due to the increase in value of the transferee바카라 사이트™s estate again the loss to the transferor바카라 사이트™s estate will be the same as the increase invalue of the transferee바카라 사이트™s estate. The straightforward forgiveness of a loan is an example. But this provision may be relevant in other circumstances, such as the omission to exercise a right (IHTM14810). The loss to the transferor바카라 사이트™s estate may not always equal the increase in the individual바카라 사이트™s estate.
You should refer to Technical any case where IHTA84/S3A (2)(b) appears to apply but the loss to the transferor바카라 사이트™s estate exceeds the increase in the transferee바카라 사이트™s estate.