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HMRC internal manual

Inheritance Tax Manual

Step 4 - grossing up position where (additional) legacies are given under a variation accepted as within IHTA84/s142

If a variation (IHTM35011) accepted as within IHTA 1984 s142 specifies that the gift is subject to tax, it will not be grossed up.

If it makes it clear that the tax will be borne by the estate as part of the testamentary expenses, the gift should be grossed up

If the variation does not say where the burden of tax should fall, you should ask who will pay the tax on the gift, and proceed as above. If, exceptionally, the tax will be paid by the original beneficiary, the payment of the tax will constitute a potentially exempt transfer (PET) (IHTM04057) by that person.