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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: future payments: payments outstanding at death

Where the transferor dies before all the payments have been made, it falls upon the legal personal representatives (IHTM05012) to complete those payments.

You can

  • give an allowance in valuing the transferor’s estate immediately before the death for the non-gratuitous part of the remaining payments, but
  • charge tax on the gratuitous portion.

Review the separate instructions at the liabilities section of the manual. (IHTM28110)