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HMRC internal manual

Inheritance Tax Manual

Step 4 - grossing up: background

Working out the tax liability involves two distinct processes:

  • valuing the chargeable transfer (IHTM26002), and
  • calculating the tax liability (IHTM31000) on that value.

These two processes are completely separate. It is essential for you to remember this when grossing up (IHTM26003).

Grossing up is the term used to describe the process of calculating the chargeable part of the estate in accordance with IHTA84/S38

  • when the partly-exempt transfer rules (IHTM26071) apply, and
  • a chargeable beneficiary takes a specific gift free of tax.

Although grossing up involves tax calculations, it is part of the process of valuing the chargeable transfer and is not part of the assessing process. The grossing calculations are governed by special rules (IHTM26123) which distinguish them from the normal rules governing tax calculations on death.

IHTA84/S40 provides a special rule where the deceased’s death estate includes property chargeable under more than one title, such as free estate (IHTM26003) or settled property or joint property passing by survivorship. In the grossing calculations the property chargeable under each title (IHTM26211), referred to in IHTA84/S40 as ‘different funds’, is looked at separately and in isolation.