Donations to the UK Independence Party made by an individual and companies he controlled did not qualify for the inheritance tax exemption for gifts to political parties. 
 
The appellant and companies he controlled made donations to the UK Independence Party (UKIP) between 7 October 2014 and 31 March 2015. The donations constituted transfers of value (within IHTA 1984, s 3), and the transfers of value comprising the donations made by the companies controlled by the appellant fell to be treated as having been made by him (under s 94).  
 
At the UK general election preceding each of these donations (i.e. on 6 May 2010), UKIP did not succeed in having any of its candidates elected as members of Parliament. Consequently, the donations did not meet the conditions for inheritance tax (IHT) exemption in IHTA 1984, s 24 (‘Gifts to political parties’).  
 
However, the appellant