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In 1996 Sir John and Lady Smith took out three life assurance policies coupled with three annuities with Equitable Life with benefits of the policies being vested in the couple's three children.
Prior to issuing the annuities as required Sir John underwent a medical examination with his GP.
Lady Smith died in 2002 and her husband died in 2003.
HMRC determined that the issue of life assurance policies at the same time as the annuities and the vesting of those policies under the trust declarations was a transfer of value under IHTA 1984 s 263 i.e. they were associated operations.
On appeal the Special Commissioner agreed with HMRC. He held that the full medical evidence required in Statement of Practice E4 as to the interpretation of s 263 had not been provided.
The appellants appealed on the ground that the...
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