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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: specific lifetime reliefs: disallowed debts: when double charges relief arises

Relief under the Inheritance Tax (Double Charges Relief) Regulations 1987 (SI 1987/1130) Reg.6 will apply where the deceased made a failed potentially exempt transfer (IHTM14511) or immediately chargeable lifetime transfer (IHTM04067) which:

  • increased the estate of the transferee, or
  • resulted in property becoming comprised in a settlement,

and before their death the deceased incurred a liability to:

  • the transferee, or
  • the trustees of the settlement,
  • which is a liability reduced or disallowed under FA86/S103. (IHTM28361