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Not all transfers of value to charities or other exempt bodies qualify for the exemptions described in those articles. A number of restrictions are set out in IHTA 1984, s 23(2)–(5) with respect to the charity exemption, and applied by reference by the sections which enact the other exemptions¹. Those which are common to all the exemptions referred to in I4.215–I4.218 are as follows:

1. Ìý

   (a)ÌýÌýÌýÌý The gift must not take effect on the termination, after the transfer of value, of any interest or period²

2. Ìý

   (b)ÌýÌýÌýÌý The gift must not depend on a condition which is not satisfied within 12 months after the transfer³

3. Ìý

   (c)ÌýÌýÌýÌý The gift must not be defeasible. Whether a gift is defeasible is determined 12 months after the transfer⁴

4. Ìý

   (d)ÌýÌýÌýÌý The interest given must not be less than the donor's interest⁵. For example, a gift of a leasehold interest in 'Black Acres' would not attract an exemption where the donor also owned the freehold

5. Ìý

   (e)ÌýÌýÌýÌý The