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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: the charge to tax: additional charges: value for tax

The value for tax, where additional charges are concerned, is the same as the value for the IHT charge at the time of transfer, except in cases where there is

The value includes any grossing (IHTM14593) addition made at that time: the tax on the grossing addition was borne by the transferor, and so was in effect a further gift by the transferor. But any additional tax payable because of the transferor’s death within seven years of the transfer is not a liability of the transferor (it is primarily a liability of the transferee), so there can be no further grossing in respect of the additional tax.