HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: the charge to tax: grossing: tax paid after the death of the transferor

You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.


  • no tax was paid in the transferor’s lifetime, and
  • following the death the transferor’s personal representatives pay the tax,

you gross-up the lifetime transfer. The instalment facility is not available. (IHTM30191)

In this situation the lifetime tax is a liability deductible against the transferor’s death estate. Where a non-death caseworker deals with the matter separately, they should draw the point to the attention of the caseworker dealing with the death estate.