Heritage property: chargeable events under IHTA84/S32
The events that cause a charge to tax in respect of a conditionally exempt transfer of assets that are not associated with each other are
- failure to observe the undertaking given to secure conditional exemption, IHTA84/S32 (2),
- death of the person beneficially entitled (IHTM04031) to the property, IHTA84/S32 (3)(a), or
- disposal of the property, by sale, gift or otherwise, IHTA84/S32 (3)(b).
It is also possible for the same event to give rise to a double charge (IHTM04118) under IHTA84/S32, or to give rise to a charge under IHTA84/S32 and in connection with a pre-1976 death.
Where this applies, HMRC may choose which chargeable event to pursue, IHTA84/S33 (5)(c). You should refer to Heritage for advice. You should also ask them for advice where a pre-1976 death is involved.