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HMRC internal manual

Inheritance Tax Manual

Woodlands: Summary

Where woodland relief (IHTM03471) is available, the person liable for the tax may elect to exclude the value of the trees or underwood (but not the land itself) from the value transferred by the chargeable transfer on the deceased’s death. Instead they will pay tax when the trees are disposed of, e.g. by sale or gift, unless the sale is to the disposer’s spouse or civil partner (IHTM11032).

This deferred charge (IHTM04122) on disposal runs only until the land on which the trees were growing forms part of a chargeable transfer (IHTM04027) on another death. If there has not been a disposal between the two deaths, the deferred charge by reference to the earlier death is extinguished (without any tax becoming due) by the chargeable transfer on the later death.