Partial exemption — examples 1 to 8.
Example 1 — gifts in excess of spouse exemption
T (having made no previous transfers) dies in 2024, domiciled in the UK leaving a legacy of chattels worth £200,000 and a legacy of shares worth £230,000 in a private company to his non-domiciled wife, directing that these legacies should bear their own tax. He also gave his wife a legacy of £45,000 free of tax. Residue is given to charity. No election is made for his spouse to be treated as UK domiciled.
The total value of the gifts to the non-domiciled spouse is £475,000, and the excess over the exempt £325,000 amount is £150,000. This reduces first the pecuniary legacy (because it is free of tax).
The remainder of the excess (£150,000–£45,000 = £105,000) is divided as to £48,838 ((200/430 × 105,000) to the gift of chattels, and as to the remaining £56,162 ((230/430) × 105,000) to the specific legacy of the shares.
The chargeable and exempt parts of the transfer are as follows:
| Exempt | | Chargeable | |
| chattels | £151,162 | | £48,838 | |
| shares | £173,838 | | £56,162 | |
| pecuniary |
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Web page updated on 17 Mar 2025 16:04