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Question 1 · Course practice question · IHT on gifts and death2 marks

Inheritance tax on lifetime gifts and death, and its payment

The inheritance tax annual exemption is £3,000 a tax year. The current year's exemption is used first, then any unused exemption of the previous tax year only.

On 1 August 2021 Sami gave quoted shares worth £426,000 to his son. It was his only lifetime gift, and he made no gifts in 2020/21. Sami died on 15 February 2026. His son still owned the shares, which were then worth £376,000.

Assume the nil rate band was £325,000 at all relevant times.

What inheritance tax is payable by Sami's son on the gift as a result of Sami's death? (2 marks)

What the syllabus covers

Income and income tax, with overseas aspects, trusts and reliefs
Chargeable gains and capital gains tax
Inheritance tax, including trusts
Corporation tax, with overseas and group aspects
Stamp taxes
VAT, tax administration and the UK tax system
The impact of taxes on situations and courses of action
Minimising and deferring tax by standard planning measures

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		Normal rates	Dividend rates
Basic rate	£1 – £37,700	20%	8·75%
Higher rate	£37,701 – £125,140	40%	33·75%
Additional rate	£125,141 and over	45%	39·35%
Savings income nil rate band – Basic rate taxpayers			£1,000
Savings income nil rate band – Higher rate taxpayers			£500
Dividend nil rate band			£500

	£
Personal allowance	12,570
Transferable amount	1,260
Income limit	100,000

Days in UK	Previously resident	Not previously resident
Less than 16	Automatically not resident	Automatically not resident
16 to 45	Resident if 4 UK ties (or more)	Automatically not resident
46 to 90	Resident if 3 UK ties (or more)	Resident if 4 UK ties
91 to 120	Resident if 2 UK ties (or more)	Resident if 3 UK ties (or more)
121 to 182	Resident if 1 UK tie (or more)	Resident if 2 UK ties (or more)
183 or more	Automatically resident	Automatically resident

The relevant base level of CO2 emissions is 55 grams per kilometre.
The percentage rates applying to petrol cars (and diesel cars meeting the RDE2 standard) with CO2 emissions up to this level are:
51 grams to 54 grams per kilometre	16%
55 grams per kilometre	17%
The percentage for electric cars with zero CO2 emissions is 3%.
For hybrid-electric cars with CO2 emissions between 1 and 50 grams per kilometre, the electric range of the car is relevant:
130 miles or more	3%
70 to 129 miles	6%
40 to 69 miles	9%
30 to 39 miles	13%
Less than 30 miles	15%

Annual allowance 2022/23	£40,000
2023/24 to 2025/26	£60,000
Minimum allowance	£10,000
Threshold income limit	£200,000
Income limit	£260,000

Plant and machinery
Main pool	18%
Special rate pool	6%
Cars
New cars with zero CO2 emissions	100%
Second-hand cars with zero CO2 emissions	18%
CO2 emissions between 1 and 50 grams per kilometre	18%
CO2 emissions over 50 grams per kilometre	6%
Annual investment allowance
Rate of allowance	100%
Expenditure limit	£1,000,000
Enhanced capital allowances for companies
Main pool first year allowance	100%
Special rate pool first year allowance	50%
Structures and buildings allowance
Straight line allowance	3%

Financial year	2023	2024	2025
Small profits rate	19%	19%	19%
Main rate	25%	25%	25%
Lower limit	£50,000	£50,000	£50,000
Upper limit	£250,000	£250,000	£250,000
Standard fraction	3/200	3/200	3/200

Standard rate	20%
Registration limit	£90,000
Deregistration limit	£88,000

Days late	Penalty
Up to 15 days	None
16 to 30 days	3%
More than 30 days	6% plus a daily penalty at an annual rate of 10%

Nil rate band	£325,000
Residence nil rate band	£175,000
Rate of tax on excess over nil rate band – Lifetime rate	20%
– Death rate	40%

Years before death	Percentage reduction
More than 3 but less than 4 years	20%
More than 4 but less than 5 years	40%
More than 5 but less than 6 years	60%
More than 6 but less than 7 years	80%

Lifetime limit – business asset disposal relief	£1,000,000
investors’ relief	£1,000,000
Rate of tax	14%

Class 1 Employee	£1 – £12,570 per year	Nil
	£12,571 – £50,270 per year	8%
	£50,271 and above per year	2%
Class 1 Employer	£1 – £5,000 per year	Nil
	£5,001 and above per year	15%
	Employment allowance	£10,500
Class 1A		15%
Class 4	£1 – £12,570 per year	Nil
	£12,571 – £50,270 per year	6%
	£50,271 and above per year	2%

Official rate of interest	3·75%
Rate of interest on underpaid tax	8·50%
Rate of interest on overpaid tax	3·50%

Taxpayer behaviour	Maximum penalty	Minimum penalty – unprompted disclosure	Minimum penalty – prompted disclosure
Deliberate and concealed	100%	30%	50%
Deliberate but not concealed	70%	20%	35%
Careless	30%	0%	15%

Up to 10,000 miles	45p
Over 10,000 miles	25p

Up to £150,000	0%
£150,001 – £250,000	2%
£250,001 and above	5%