Considering the decision in HMRC v. Parry [2020] UKSC 35, while the subjective intentions of the donor are relevant to determining whether s.10(1) Inheritance Tax Act 1984 (dispositions not intended to confer gratuitous benefit) applies, donations to further a political objective are still transfers of value and subject to Inheritance Tax – a donor ‘…cannot convert a gratuitous benefit into a contract for consideration simply because he subjectively considers that he did receive something in return… whether that be an opportunity to input into the campaigns, the advancement of his political and financial goals or any.other intangible benefit…’: https://caselaw.nationalarchives.gov.uk/ukftt/tc/2026/589
Charles Cooper | Barrister 