The taxpayer and his companies made donations to the UK Independence party (UKIP) in 2014 and 2015. It was accepted that the donations were ‘transfers of value’ within IHTA 1984 s 3. It was also agreed that the transfers of value made by the companies controlled by the taxpayer could be treated as made by him under s 94.
The dispute concerned whether the donations qualified for exemption from inheritance tax under s 24 (gifts to political parties). The provision covers donations to a political party that at the last election preceding the transfer had at least two MPs or one seat and 150 000 votes. At the 2010 general election – the one preceding the date on which the donations were made – UKIP had no MPs. Therefore HMRC said the taxpayer did not qualify for the exemption.
The First-tier Tribunal dismissed the taxpayer’s appeal.
The taxpayer...
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