{
  "url": "https://openlegislation.uk/inheritance-tax-avoidance-schemes-prescribed-descriptions-of-arrangements-regulations-2017/regulation-4",
  "json_url": "https://openlegislation.uk/inheritance-tax-avoidance-schemes-prescribed-descriptions-of-arrangements-regulations-2017/regulation-4.json",
  "legislation": "uksi/2017/1172",
  "legislation_title": "The Inheritance Tax Avoidance Schemes (Prescribed Descriptions of Arrangements) Regulations 2017",
  "legislation_url": "https://openlegislation.uk/inheritance-tax-avoidance-schemes-prescribed-descriptions-of-arrangements-regulations-2017",
  "path": "regulation/4",
  "kind": "regulation",
  "number": "4",
  "heading": "Prescribed description of arrangements in relation to inheritance tax",
  "text": "(1) Arrangements fall within the description in this regulation if it would be reasonable to expect an informed observer (having studied the arrangements and having regard to all relevant circumstances) to conclude that condition 1 and condition 2 are met.\n(2) Condition 1 is that the main purpose, or one of the main purposes, of the arrangements is to enable a person to obtain one or more of the following advantages in relation to inheritance tax (the “tax advantage”)—\n(a) the avoidance or reduction of a relevant property entry charge;\n(b) the avoidance or reduction of a charge to inheritance tax under section 64, 65, 72 or 94 of IHTA 1984;\n(c) the avoidance or reduction of a charge to inheritance tax arising from the application of section 102, 102ZA, 102A or 102B of the Finance Act 1986 in circumstances where there is also no charge to income tax under Schedule 15 to the Finance Act 2004 (charge to income tax on benefits received by former owner of property);\n(d) a reduction in the value of a person’s estate without giving rise to a chargeable transfer or potentially exempt transfer.\n(3) Condition 2 is that the arrangements involve one or more contrived or abnormal steps without which the tax advantage could not be obtained.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "footnote",
      "label": "f1",
      "text": "1986 c. 41. Sections 102A and 102B were inserted by the Finance Act 1999 section 104; section 102ZA was inserted by paragraph 33 of Schedule 20 to the Finance Act 2006 (c. 25)."
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2017/1172/regulation/4",
    "retrieved_at": "2026-10-28T23:05:43.799030+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."
}