Revenue and Customs v Parry and Others: SC 19 Aug 2020

Whether the pension scheme transfer by the late Mrs Staveley, and her omission to take income benefits which were then payable, constituted, or are to be treated as constituting, for the purposes of the Inheritance Tax 1984 a ‘disposition’ which is a ‘transfer of value’ in favour of her sons, who were to be the beneficiaries of the death benefit.
Held: Taxpayer’s appeal failed.
Lord Reed, Lord Hodge, Lady Black, Lord Kitchin, Lord Sales
[2020] UKSC 35
Bailii, Bailii Summary, Bailii Issues and Facts
Inheritance Tax 1984 3(1) 3(3) 10(1)
England and Wales
Citing:
At FTTTxParry and Others v Revenue and Customs FTTTx 7-May-2014
INHERITANCE TAX – transfer of funds to personal pension plan while diagnosed with terminal cancer – whether transfer of value – omission to take lifetime benefits – whether disposition and transfer of value – appeal allowed in part . .
At UTTCRevenue and Customs v Representatives of Staveley (Deceased) UTTC 10-Jan-2017
Failure to take pension benefits – Inheritance Tax
UTTC INHERITANCE TAX – whether transfer of funds to a personal pension plan was a transfer of value – Inheritance Tax Act 1984, s 3(1) and s 10 – whether deceased’s omission to take lifetime pension benefits was . .
Appeal from (CA)Revenue and Customs v Parry and Others CA 16-Oct-2018
Pension Accumulation was taxable
The court was asked whether the pension scheme transfer by the late Mrs R F Staveley, and her omission to take income benefits which were then payable, constituted, or are to be treated as constituting, for the purposes of Inheritance Tax 1984 . .

Lists of cited by and citing cases may be incomplete.
Updated: 24 August 2021; Ref: scu.653118