F6 – Nil Rate Band question – BPP Question 28 Artem

Below are the relevant parts of the question which I am doing wrong.

My question is for gift on “17 January 2009” why they used “323,000” rather “336000” which is actually gift amount given in question?

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QUESTION – 28 Artem

Artem died on 15 December 2013. During his lifetime he made the following cash gifts:

Date Donee £
10 December 2005 Daughter 65,000
17 January 2009 Trust (Artem paid the lHT) 336,000
15 February 2010 Nephew 200
18 August 2010 Sister 49,000

Required

(a) Explain the inheritance tax implications of these gifts during Artem‘s lifetime and compute any lifetime inheritance tax payable.

Nil rate bands
2005/06 £275,000
2008/09 £312,000
2009/10 onwards £325,000

BPP ANSWER:

17 January 2009

The first £6,000 of this transfer is an exempt transfer because of the annual exemptions for 2008/09 and 2007/08.

The remaining £(323,000 – 6,000) = 317,000 Is a chargeable lifetime transfer because it is not a transfer to another individual.

This Is the first chargeable transfer that Artem makes and so the nil rate band is available in full.

The inheritance tax on this transfer ls: 317.000

Net transfer of value (Artem pays lHT)
IHT £312,000 x 0% = Nil
£5,000 x 20/80 = 1.250

Total IHT = 1 .250