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HMRC internal manual

Inheritance Tax Manual

Heritage property: when a charge to tax arises

Where there has been a conditionally exempt transfer, tax may be subsequently payable on the first occurrence after the transfer (or if the transfer was a potentially exempt transfer, (IHTM04057) on the first occurrence after the transferor’s death) of a chargeable event, such as the sale of the asset.

The chargeable events are contained in

  • IHTA84/S32 in connection with properties that are not associated (IHTM04113) with each other, and
  • IHTA84/S32A where the event concerns properties that are associated (IHTM04115) with each other.

Because of the definition of a conditionally exempt transfer, the charging provisions of IHTA84/S32 and IHTA84/S32A only apply to chargeable events in relation to property conditionally exempted on a transfer on or after 7 April 1976.