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HMRC v Parry and others

In HMRC v Parry and others [2018] EWCA Civ 2266 (16 October 2018) the Court of Appeal found that a transfer from a s 32 buyout pension policy to a personal pension policy with a statement of wishes identifying beneficiaries was a transfer of value for IHT purposes which did not fall within the purchase exemption (IHTA 1984 s 10(1)).

Mrs Staveley had built up a company M Ltd with her husband. They divorced and as part of a settlement for the divorce M Ltd granted her a pension in the form of a ‘section 32 buyout policy’ (a pension policy under FA 1981 s 32). In October 2006 within two months of her death she transferred this policy to a personal pension policy issued by AXA (the ‘PPP’). If Mrs Staveley's pension had remained in the original policy on...

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