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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Allocating the burden of tax: practice

Once the Inheritance Tax due on a partly exempt transfer has been calculated, the personal representatives (IHTM05012) have to decide how that tax is to be borne. Working out how much of the tax is to come out of each beneficiary’s interest in the estate is a matter of administration. So it is for the personal representatives to decide and you should not normally offer an opinion on it. If the personal representatives ask for guidance, you should deal with their questions as briefly as you can. If you have difficulty, refer the case to your manager.