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HMRC internal manual

Inheritance Tax Manual

Heritage property: chargeable events under IHTA84/S32A

The events that cause a charge to tax on a conditionally exempt transfer of properties that are associated with each other are

  • failure to observe the undertaking given to secure conditional exemption, IHTA84/S32A (3),
  • death of the person beneficially entitled (IHTM04031) to the assets, IHTA84/S32A (4)(a), or
  • disposal of the assets, by sale, gift or otherwise, IHTA84/S32A (4)(b).

However, you should note that though the event may apply only to one of the associated properties, the charge arising under IHTA84/S32A will apply to the all of the properties that are associated with each other.

There are a number of special situations (IHTM04117) that apply and the events are subject to a number of exceptions (IHTM04116).

It is also possible for the same event to give rise to a double charge (IHTM04118) under IHTA84/S32A, or to give rise to a charge under IHTA84/S32A and in connection with a pre-1976 death.

Where this applies, the Board of 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.