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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: specific lifetime reliefs: double charges relief: applying the relief

When a double charge arises:

  • retain the charge on the transfer which produces the higher overall amount of Inheritance Tax, and
  • reduce the other transfer to nil.

There is an exception in certain discretionary trust cases (IHTM14732).

Where you:

  • retain the later transfer within the Inheritance Tax charge, and
  • tax has been paid on the earlier transfer,

you may allow credit for some or all of that tax.