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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: what is the value transferred by an immediately chargeable transfer?

The value transferred (IHTM04028) is calculated by reference to the loss to the transferor’s estate. (IHTM04054)However, note particularly the need to gross up (IHTM14541) the transfer if the transferor is paying the tax.