Date of transfer of value-unrecovered debt ?

F lends £100k. to son, repayable in two years. Money now irrecoverable. IHTA s3(3) date?

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On 1st July 2005 F lent £100k to son on  documented terms that the debt is repayable on 1st July 2007. For various reasons debt is not repaid on due date . Father and son are not in contact.

On what date is father deemd to have made a transfer of value under IHTA s3(3)? Is it 1st. July2011, 1st July 2013 or some other date?

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