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HMRC internal manual

Inheritance Tax Manual

Heritage property: double charges

The same event may be a chargeable event in relation to

  • 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 Section.


A dies in 1977 and bequeaths a mansion house and surrounding land to B. It is a conditionally exempt transfer of the house and land. In 1983, B settles the both properties on discretionary trusts. Again it is a conditionally exempt transfer. In 1990, the trustees sell both the house and land by auction. The sale is a chargeable event in respect of both conditionally exempt transfers.