HMRC internal manual

Inheritance Tax Manual

IHTM14705 - Lifetime transfers: specific lifetime reliefs: potentially exempt transfers (PETs): Quick Succession Relief (QSR)

Double charges relief may be in point where the transferee has died and under their Will or intestacy the gifted asset is returned to the transferor.

If tax was paid on the transferee’s death, quick succession relief (QSR) (IHTM22041) will reduce the tax payable on the subsequent death of the transferor in both calculations (IHTM14692).

Further, if the PET (IHTM14511) exceeded the threshold and so itself bears tax on the transferor’s death, QSR will also be due on the transferee’s death by reference to the tax subsequently payable in respect of the PET (IHTM22080).