Under the provisions of IHTA 1984, s 27, Sch 4 a transfer of property into settlement is an exempt transfer for the purposes of inheritance tax if the income from the property so settled can be used only for the maintenance of land or buildings of historic interest or for certain other specified purposes (a maintenance fund), see I7.541–I7.546. For the purposes of capital gains tax, holdover relief1 may be claimed in respect of transfers of assets into maintenance funds which are exempt transfers for inheritance tax purposes2 or are subject to a reduced inheritance tax charge3, see C3.1601.
The claim must be made within two years after the date of the transfer concerned or within such longer period as HMRC may allow4. Subject to this, under the inheritance tax provisions5, the HMRC will direct that such a transfer is exempt if certain conditions are satisfied, namely, that:
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