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HMRC internal manual

Inheritance Tax Manual

Interest in unadministered estates: statutory provisions

IHTA84/S91 is relevant when a person (“the beneficiary”) would have beenentitled to the whole or part of the residue of the estate of a deceased person if theadministration of that estate had been completed

The effect of IHTA84/S91 is that for IHT purposes the beneficiary’s interest whetherlimited or absolute is treated as a direct interest (and not merely a right) in the assets constituting the unadministered estate.