Inheritance Tax Manual

IHTM04316 - Para 6/Schedule A1/IHTA84: targeted anti-avoidance rule and s237(2A)/IHTA: Inland Revenue charge

The provisions include a targeted anti-avoidance rule (TAAR) which applies where arrangements are entered into where the sole or main purpose of doing so is to avoid or minimise the effect of the legislation. 

There is also the ‘Inland Revenue Charge’ within IHTA84/S237. The charge for unpaid Inheritance Tax (IHT) extends to the enveloped dwelling and (on or after 6 April 2026) agricultural property. So, if the IHT is unpaid then HMRC has the authority to register a charge against the property at the HM Land Registry, even though the property itself is owned by a company or partnership and not by the individual or trustee.