Malcolm Finney examines the inheritance tax treatment of gifts to companies, and also by companies.
Inheritance tax (IHT) is levied on lifetime gifts, albeit subject to certain reliefs (e.g., business property relief, in IHTA 1984, s 103) and exemptions (e.g., the annual exemption, in IHTA 1984, s 19). Primarily, such gifts are made by individuals to other individuals, although gifts by individuals to various types of trust (e.g., a relevant property or interest in possession trust) are not uncommon. Trustees may also appoint trust assets out to trust beneficiaries, which perhaps can be viewed as gifts by trustees.
However, what of the IHT treatment of gifts made to or by companies?
Gifts by companies
Gifts made by companies (unlike gifts between individuals) are not potentially exempt transfers (PETs) and, indeed, do not qualify as chargeable transfers of value.
