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.

Where:

  • 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.