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HMRC internal manual

Inheritance Tax Manual

Liabilities: investigating liabilities: payment of annuity is the personal responsibility of the deceased or transferor

In this case the annuity is simply a debt due from the deceased. In accordance with the decision in Westminster Bank v IRC [1954] WLR 242 the value of the annuity should be calculated by reference to the cost of purchasing an annuity from the National Debt Commissioners. These calculations will be made by the Actuarial Team. But before you refer this to the Actuarial Team you should ask the taxpayer to state:

  • the precise circumstances under which the annuity is payable
  • the date of birth of the annuitant
  • the gender of the annuitant
  • the frequency of payment of the annuity, and
  • how the value (if any has been provided) has been calculated.