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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Constables and service personnel targeted because of their job: summary

IHTA84/S155A provides an exemption from Inheritance Tax (as set out in IHTM11282) for constables and service personnel, including civilians subject to service discipline, who die as a result of being deliberately targeted because of their job. The exemption also applies to retired constables and service personnel etc who die in such circumstances through the reference to former constables etc.

The exemption applies where a constable or former constable dies

  • from an injury sustained or disease contracted in circumstances where they were deliberately targeted as a result of their job, IHTA84/S155A(1)(a), or
  • from a disease contracted at some previous time, the death being due to, or hastened by, the aggravation of the disease by an injury sustained or a disease contracted through being deliberately targeted as above, IHTA84/S155A(1)(b).

The equivalent provisions for service personnel (IHTM11312) is at IHTA84/S155A(2).

There is no time limit on when the injury or disease was incurred, and it does not matter whether the deceased was acting in the course of their duties as a constable or service person when the injury was sustained or the disease contracted, IHTA84/S155A(4).

This exemption does not apply where either IHTA84/S153A or IHTA84/S154 applies to the deceased’s death, IHTA84/S155A(6). So it will primarily apply where a constable or service person is injured or dies when they are off duty or attending non-emergency circumstances and an attack on them was driven by the nature of their job. It would apply in circumstances similar to those resulting in the death of Fusilier Lee Rigby in 2013 and of PCs Nicola Hughes and Fiona Bone in 2012.