Inheritance Tax Manual

IHTM46012 - Basic definitions: the value of the estate 바카라 사이트˜E바카라 사이트™ and the value transferred on death 바카라 사이트˜VT바카라 사이트™

For residence nil-rate band (RNRB), the 바카라 사이트˜qualifying residential interest바카라 사이트™ (IHTM46011) must be part of the person바카라 사이트™s estate immediately before the person바카라 사이트™s death. The definition of 바카라 사이트˜estate바카라 사이트™ for RNRB is the normal inheritance tax definition contained in IHTA84/S5 (IHTM04029). A person바카라 사이트™s estate is the aggregate of all the property to which a person is beneficially entitled. A person바카라 사이트™s estate on death includes settled property in which the person had a qualifying interest in possession (IHTM16060) and any gift with reservation (GWR) (IHTM14301) property, but does not include excluded property.

The RNRB legislation refers to the value of a person바카라 사이트™s estate on death as 바카라 사이트˜E바카라 사이트™. This value takes into account any debts and liabilities that are taken into account in accordance with IHTA84/S5 (IHTM28381), but takes no account of any exemptions, or reliefs such as agricultural relief (IHTM24001) or business relief (IHTM25131).

Reliefs for the loss on sale of shares (IHTM34010) or land (IHTM33010) however are taken into account in the value of 바카라 사이트˜E바카라 사이트™ as they substitute the sale price of the asset in question for its date of death value. It may therefore be particularly important to take this into account when re-calculating a RNRB claim following a loss on sale claim where the value of 바카라 사이트˜E바카라 사이트™ had previously exceeded the taper threshold (IHTM46023).

The RNRB legislation also refers to the value transferred by the chargeable transfer on death, which is referred to as 바카라 사이트˜VT바카라 사이트™ 바카라 사이트“ IHTA84/S8D(5)(e). This is the value of the chargeable transfer on death. That is the value of the estate after taking into account any exemptions and reliefs. It does not include the value of any chargeable lifetime transfers or failed PETs which aggregate with the estate on death.

Example

The deceased바카라 사이트™s estate includes assets worth £1,200,000 and liabilities of £20,000. There is a legacy to charity of £100,000 which is exempt.

The value of the deceased바카라 사이트™s estate is the value of the assets (£1,200,000) less the value of the liabilities (£20,000) = £1,180,000. This is 바카라 사이트˜E바카라 사이트™

The value transferred by the chargeable transfer on death is the net value of the estate (£1,180,000) less the exemption for the legacy to charity (£100,000) = £1,080,000. This is 바카라 사이트˜VT바카라 사이트™.