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HMRC internal manual

Inheritance Tax Manual

Transfers on death: the charging provisions

The basic provision governing the tax charge on death is IHTA84/S4 (1). The charge may be divided into two parts. The subsection provides that on the death of any person (the deceased) tax is charged as if the deceased

  • had made a transfer of value (IHTM04042) immediately before death, and
  • the value transferred had been equal to the value of the deceased’s estate (IHTM04043) immediately before his death.