{
  "url": "https://openlegislation.uk/inheritance-tax-act-1984/schedule-A1/paragraph-5",
  "json_url": "https://openlegislation.uk/inheritance-tax-act-1984/schedule-A1/paragraph-5.json",
  "legislation": "ukpga/1984/51",
  "legislation_title": "Inheritance Tax Act 1984",
  "legislation_url": "https://openlegislation.uk/inheritance-tax-act-1984",
  "path": "schedule/A1/paragraph/5",
  "kind": "paragraph",
  "number": "5",
  "heading": null,
  "text": "(1) This paragraph applies to—\n(a) property which constitutes consideration in money or money's worth for the disposal of property to which paragraph 2 or paragraph 3(a) applies;\n(b) any money or money's worth paid in respect of a creditor's rights falling within paragraph 3(a);\n(c) any property directly or indirectly representing property within paragraph (a) or (b).\n(2) If and to the extent that this paragraph applies to any property—\n(a) for the two-year period it is not excluded property by virtue of section 6(1), (1A) or (2) , section 48(4) or section 48ZA, and\n(b) if it is held in a qualifying foreign currency account within the meaning of section 157 (non-residents' bank accounts), that section does not apply to it for the two-year period.\n(3) The two-year period is the period of two years beginning with the date of—\n(a) the disposal referred to in sub-paragraph (1)(a), or\n(b) the payment referred to in sub-paragraph (1)(b).\n(4) The value of any property within sub-paragraph (1)(c) is to be treated as not exceeding the relevant amount.\n(5) The relevant amount is—\n(a) where the property within sub-paragraph (1)(c) directly or indirectly represents property within sub-paragraph (1)(a) (“the consideration”), the value of the consideration at the time of the disposal referred to in that sub-paragraph, and\n(b) where the property within sub-paragraph (1)(c) directly or indirectly represents property within sub-paragraph (1)(b), the amount of the money or money's worth paid as mentioned in that sub-paragraph.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. A1 inserted (with effect in accordance with Sch. 10 para. 9 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 10 para. 1 (with Sch. 10 para. 9(2))"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in Sch. A1 para. 5(2)(a) substituted (6.4.2025) by Finance Act 2025 (c. 8), Sch. 13 paras. 29(3), 45(1)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/1984/51/schedule/A1/paragraph/5",
    "retrieved_at": "2026-10-29T10:01:12.914001+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}