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Parry and others v HMRC

In Parry and others v HMRC (TC03548 – 7 May 2014) the FTT held that a transfer of funds to a personal pension plan (PPP) was not a transfer of value for IHT purposes.

Following an acrimonious divorce Mrs Staveley (the deceased) had received as ancillary relief her share of a company pension fund. She had then been advised to transfer her fund into a ‘s 32 buyout’.

Following changes in the legislation Mrs Staveley was advised that she could transfer her fund into a PPP after six years and she did so on 30 October 2006. At the time she was terminally ill with cancer. She died on 18 December 2006.

HMRC issued a first notice of determination as it considered that the 2006 transfer was a transfer of value of £405 694. A second notice of determination was issued on the basis...

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