Holdover applies in two situations. Under s260 Taxation of Chargeable Gains Act (TCGA) 1992 on a lifetime gift where inheritance tax is payable upfront - most commonly on a gift to a discretionary trust - the relief is available even where the gift to the discretionary trust is within the donor's nil rate band, that is, where no IHT is actually payable. |
Taxpayers who want to save IHT and who have children under 18 should seriously consider setting up suitable trusts before April 6, 2006. |