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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: specific lifetime reliefs: potentially exempt transfers (PETs): when double charges relief arises

The relief Inheritance Tax (Double Charges Relief) Regulations 1987 (SI1987/1130) Reg.4 covers cases where the deceased had made a PET (IHTM14511) which has become chargeable, and immediately before the death was beneficially entitled to assets which:

  • the deceased had acquired from the transferee otherwise than for full consideration in money or money’s worth
  • are the assets transferred by the PET or represent that property
  • are comprised in the deceased’s estate and is the subject of a chargeable transfer on death.

Apply the relief (IHTM14692) in these circumstances as usual.