Chapter IHTM14336

Published date20 March 2016
Record NumberIHTM14336
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

Except in the case of land or chattels (IHTM14341), the fact that the donor gave full consideration for the benefit or enjoyment which they obtained will not be sufficient to say that there is no reservation.

Example

Alex, who is a partner, withdraws capital from his partnership capital account and gives it to Bella. Bella then lends the partnership an equivalent cash sum.

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