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HMRC internal manual

Inheritance Tax Manual

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HM Revenue & Customs
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Successive transfers: Examples of relief

Example 1

The facts in the example at IHTM24123 also illustrate the operation of IHTA84/S121

  • assuming Longacre was situated in England, the four conditions for successive transfers (IHTM24153) are satisfied on the death of A’s widow, so relief would have been available under S121 even if it had not been available with the occupation condition being satisfied through IHTA84/S120 (1), but
  • if Longacre had been situated in Scotland, and so occupied by a Scottish partnership, the occupation requirement in IHTA84/S121 (1)(b) is satisfied only if IHTA84/S119 (2) applies. You should seek advice from Technical on any case where the relationship between IHTA84/S121 (1)(b) and IHTA84/S119 (2) is in point.

Example 2

The example at IHTM24102, illustrates the operation of IHTA84/S121 where the ownership is of a reversionary interest.

Example 3

The example at IHTM24111, illustrates the operation of IHTA84/S121 where the replacement property provisions are in point.