Section 62A — Inheritance Tax Act 1984: Same-day additions

Same-day additions 62A 1 For the purposes of this Chapter, there is a “ same-day addition ”, in relation to a settlement (“settlement A”), if—

a there is a transfer of value by a person as a result of which the value immediately afterwards of the property comprised in settlement A is greater than the value immediately before, b as a result of the same transfer of value, or as a result of another transfer of value made by that person on the same day, the value immediately afterwards of the property comprised in another settlement (“settlement B”) is greater than the value immediately before, c that person is the settlor of settlement A and settlement B, d at any point in the relevant period, all or any part of the property comprised in settlement A was relevant property, and e at that point, or at any other point in the relevant period, all or any part of the property comprised in settlement B was relevant property. For exceptions, see section 62B.

2 Where there is a same-day addition, references in this Chapter to its value are to the difference between the two values mentioned in subsection (1)(b). 3 “ The relevant period ” means—

a in the case of settlement A, the period beginning with the commencement of settlement A and ending immediately after the transfer of value mentioned in subsection (1)(a),

and b in the case of settlement B, the period beginning with the commencement of settlement B and ending immediately after the transfer of value mentioned in subsection (1)(b)).

4 The transfer or transfers of value mentioned in subsection (1) include a transfer or transfers of value as a result of which property first becomes comprised in settlement A or settlement B; but not if settlements A and B are related settlements.

5 For the purposes of subsection (1) above, it is immaterial whether the amount of the property comprised in settlement A or settlement B (or neither) was increased as a result of the transfer or transfers of value mentioned in that subsection.