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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Step 3 - interaction: the appropriate fraction

All specific gifts other than those of relievable property are reduced proportionately by using the appropriate fraction at IHTA84/S39A (4). The fraction can be expressed in two alternative ways depending on whether there are

  • specific gifts of relievable property (IHTM26110), or
  • no specific gifts of relievable property (IHTM26109)

The fraction is based solely on property at the title (IHTM26211) you are concerned with, normally the free estate (IHTM26003). Property chargeable at any other title, such as settled property (IHTM16000), is excluded.