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HMRC internal manual

Capital Gains Manual

Death and Personal Representatives: Valuation of assets at date of death and associated liaison with Specialist PT-IHT: Ascertained values: Valuation of assets: ascertained values: meaning of 'on the death'

TCGA1992/S274 only applies ‘where on the death of a person inheritance tax is chargeable on the value of his estate immediately before death.’  It therefore does not apply:

  • Where the liability to IHT occurs on a lifetime chargeable transfer such as a gift into a settlement,
  • Where the liability is in respect of what was initially a Potentially Exempt Transfer (IHTM04057), even though a charge arises because the donor has failed to survive seven years (IHTM14511).