I take it that Malcolm seems to confirm that both calculations in this example include the full NRB and this follows from reg 5(5) which reduces the value of the ignored item to nil
AsI read it however, Jack seems to consider that only the balance of the NRB if any is applied to the second deemed PET Reading the Regulation however I cannot see anywhere where it does not permit application of the full NRB to the deemed transfer, simply because it had already reduced the comparative calculation on the earlier PET
I agree that the deemed PET calculation will however result in more tax even if the value of the property is the same because the annual exemption cannot be applied to a deemed PET
Mochael Jepson