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HMRC internal manual

Inheritance Tax Manual

Heritage property: double charges

The same event may be a chargeable event for

  • more than one conditionally exempt transfer, or
  • a conditionally exempt transfer and exemption on a death before 7 April 1976.

Any such case should be referred to Heritage.


Greta dies in 1997 and bequeaths a mansion house and surrounding land to her son, Guido. It is a conditionally exempt transfer of the house and land. In 2003, Guido settles both properties on discretionary trusts. Again it is a conditionally exempt transfer. In 2010, the trustees sell both the house and land by auction. The sale is a chargeable event in respect of both conditionally exempt transfers.