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In outline, the interaction provisions of IHTA84/S39A state the value of any specific gifts (IHTM26011) of relievable property is their value after relief (IHTA84/S39A (2)), while the value of any other specific gifts is the ‘appropriate fractionâ€� (IHTM26108) of their value (IHTA84/S39A (3)).Ìý

Under IHTA84/S39A (4) the appropriate fraction is:Ìý

• The value transferred after business or agricultural relief less any specific gifts of relievable property at their reduced valueÌý

divided byÌý

• the unreduced value transferred less any specific gifts of relievable property at their value before reductionÌý

Where grossing up (IHTM26003) is necessary, IHTA84/S39A(5) provides that the values to be grossed up are the values as reduced under IHTA84/S39A (2) to (4).Ìý

AÌýspecific gift of relievable property does not include the value of any other gift payable out of that property and that other gift is not treated as a gift of relievable property (IHTA84/S39A (6)).Ìý

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