Section 10 — Inheritance Tax Act 1984: Dispositions not intended to confer gratuitous benefit.

Dispositions not intended to confer gratuitous benefit. 10 1 A disposition is not a transfer of value if it is shown that it was not intended, and was not made in a transaction intended, to confer any gratuitous benefit on any person and either—

a that it was made in a transaction at arm’s length between persons not connected with each other, or b that it was such as might be expected to be made in a transaction at arm’s length between persons not connected with each other.

2 Subsection (1) above shall not apply to a sale of unquoted shares or unquoted debentures unless it is shown that the sale was at a price freely negotiated at the time of the sale or at a price such as might be expected to have been freely negotiated at the time of the sale.

3 In this section— “ disposition ” includes anything treated as a disposition by virtue of section 3(3) above; “ transaction ” includes a series of transactions and any associated operations.