Inheritance Tax Act 1984 section 10

Dispositions not intended to confer gratuitous benefit

Section 10 provides that certain dispositions which are not intended to confer a gratuitous benefit are excluded from being transfers of value for inheritance tax purposes, subject to special rules for unquoted shares and debentures.

• A disposition is not a transfer of value if it was not intended to confer any gratuitous benefit and was made at arm's length between unconnected persons, or on terms that might be expected in such a transaction
• For sales of unquoted shares or unquoted debentures, the exemption only applies if the sale price was freely negotiated at the time, or was a price that might be expected to have been freely negotiated
• The term "disposition" includes anything treated as a disposition under section 3(3), such as the omission to exercise a right
• The term "transaction" is broadly defined to include a series of transactions and any associated operations