Wood v Revenue and Customs (INHERITANCE TAX - transfers of value - s.10 IHTA 1984 - whether intention to confer any gratuitous benefit on any person - exempt transfers - s.21 of IHTA 1984 - whether donations were part of normal expenditure) [2026] UKFTT 589 (TC) (16 April 2026)

Wood v Revenue and Customs (INHERITANCE TAX - transfers of value - s.10 IHTA 1984 - whether intention to confer any gratuitous benefit on any person - exempt transfers - s.21 of IHTA 1984 - whether donations were part of normal expenditure) [2026] UKFTT 589 (TC) (16 April 2026)

Mr Wood's payments objectively conferred gratuitous benefits on the recipients, and he subjectively intended to do so, even if he also hoped for influence or personal benefit. The payments were not made pursuant to any settled pattern or commitment and thus did not constitute normal expenditure out of income. Therefore, the payments are transfers of value subject to inheritance tax and do not qualify for exemption under s.10 or s.21 IHTA 1984.

Citation
[2026] UKFTT 589
Parties
Appellant: Jonathan Wood; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
16 April 2026
Procedural Posture
Tax Appeal (inheritance Tax) / First Tier Tribunal (tax Chamber) Substantive Judgment
Outcome
Appeal dismissed
Legal Topics
Inheritance Tax, Transfers of Value, Exempt Transfers, Normal Expenditure Out of Income, Intention to Confer Gratuitous Benefit
Tax Law Inheritance Tax Transfers of Value Exempt Transfers Normal Expenditure Out of Income Intention to Confer Gratuitous Benefit

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Parties

Jonathan Wood

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal (inheritance Tax) / First Tier Tribunal (tax Chamber) Substantive Judgment

Legal Issues

  1. 1 Whether payments made by Mr Wood were intended to confer any gratuitous benefit under s.10 IHTA 1984 and thus not transfers of value for IHT purposes
  2. 2 Whether the payments were part of Mr Wood's normal expenditure out of income under s.21 IHTA 1984 and thus exempt transfers

Ratio Decidendi

Mr Wood's payments objectively conferred gratuitous benefits on the recipients, and he subjectively intended to do so, even if he also hoped for influence or personal benefit. The payments were not made pursuant to any settled pattern or commitment and thus did not constitute normal expenditure out of income. Therefore, the payments are transfers of value subject to inheritance tax and do not qualify for exemption under s.10 or s.21 IHTA 1984.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed. The Varied Determination of HMRC stands.