A transfer cannot be a potentially exempt transfer (PET) if, under any provision of IHTA 1984, tax is charged as if a transfer of value had been made1. This rule does not however apply in the case of a tax charge on the termination of an interest in possession except where the transfer of value on the termination is in relation to any interest in possession acquired by a UK domiciliary between 9 December 2009 and 5 April 2025 or a long-term UK resident from 6 April 2025 by virtue of a transaction that was not intended to confer gratuitous benefit. This therefore excludes the making of a transfer of value by a close company which is apportioned to the participators under the rules detailed at I6.121–I6.1292.
The only other event on which tax is charged as if a transfer of
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