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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
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Liabilities: investigating form IHT419: lifetime transfers on guarantee debts called in and fully paid before death

Lifetime transfers might have arisen if the deceased entered into an agreement to guarantee a debt within the 7 years before they died and payments under the guarantee were required and made before death. You should consider the borrower’s financial position at the date that the guarantee was given in the same way as on the previous page (IHTM28356) even though there is no outstanding liability at the date of death.

This information will not be shown on form IHT419. In strictness any lifetime transfer should be shown on form IHT403. But in many cases this will only come to light in the course of other enquiries or if other information is received. Although you should be alert to possible omissions, particularly in where unlisted companies are involved, you should not raise any enquiries unless you have evidence to suggest that a lifetime transfer has not been returned.