Inheritance Tax Act 1984 section 15

Waiver of dividends

Section 15 deals with the inheritance tax treatment of a shareholder who waives their entitlement to a dividend, ensuring that such a waiver is not treated as a transfer of value provided it is made within the required time limit.

• A waiver of a dividend on shares in a company is not a transfer of value if made within 12 months before the right to the dividend has accrued.
• The relief applies to any "person", which includes both individuals and companies.
• For British companies, a final dividend accrues when declared at general meeting, and an interim dividend accrues when it is paid.
• For foreign companies, the same accrual assumptions apply unless challenged, in which case the company's constitution or articles should be examined.