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HMRC internal manual

Inheritance Tax Manual

Successive transfers: Introduction

IHTA84/S121 contains provisions where, in certain circumstances, agricultural relief may be allowed on a second transfer even though the occupation (IHTM24070) and ownership (IHTM24100) requirements of IHTA84/S117 are not satisfied. These provisions operate as an alternative to IHTA84/S117 and dispense with the ‘minimum’ period for both the occupation and ownership tests.

In this respect, the provisions of IHTA84/S121 are quite different from those in IHTA84/S120 which apply to successions. (IHTM24120)