Inheritance Tax Act 1984 section 62A

Same-day additions

Section 62A defines what constitutes a "same-day addition" in relation to settlements, which is relevant to calculating the inheritance tax charge on relevant property trusts.

  • A same-day addition arises where the same settlor makes transfers of value on the same day that increase the value of property in two separate settlements, both of which hold or have held relevant property
  • The value of a same-day addition is the increase in value of the property in the other settlement (settlement B) resulting from the transfer
  • A transfer that creates a new settlement can count as a same-day addition, but not where the two settlements involved are related settlements (i.e. made on the same day by the same settlor)
  • A same-day addition can occur even where the amount of property in a settlement does not increase, provided the value of the property increases

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