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Subject to the exceptions set out below a transfer of value from one spouse (or civil partner) to another is exempt¹:

1. Ìý

   (a)ÌýÌýÌýÌý if it is attributable to property which becomes comprised in the estate of the transferor's spouse, it is exempt to the extent of the value transferred, or

2. Ìý

   (b)ÌýÌýÌýÌý if it has the effect of increasing the value of the spouse's estate (for example, by increasing the value of some asset held by the spouse), it is exempt to the extent of the increase

The main discussion of this exemption is in I4.225, with the special rules for transfers where spouses have a different long-term UK residence status (for transfers on or after 6 April 2025) or domicile status (for transfers before 6 April 2025) considered in I4.227, and the restrictions and anti-avoidance provisions considered in I4.228.

Exemption (b) above is far more likely to be a lifetime transfer than one made on death. The exemption is limited