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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: specific lifetime reliefs: disallowed debts: calculations producing the same amount

It may happen that each of the prescribed calculations produces the same amount of tax payable on the death.

Under Inheritance Tax (Double Charges Relief) Regulations 1987 (SI1987/1130) Reg.8, in such cases use the first calculation - the calculation which involves disregarding the lifetime charge in whole or in part.