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HMRC internal manual

Inheritance Tax Manual

Liability on death transfers: priorities

IHTA84/S200 contains no provision for determining priorities among the persons liable to tax on the transfer on death.

However IHTA84/S204 (9) contains a priority rule for tax on gifts with reservation treated as part of the death estate (IHTM30083) under FA 1986 IHTA84/S102(3). Under this section the personal representatives (IHTM05012) are liable under IHTA84/S200(1)(a) for tax on those assets only if the tax remains unpaid 12 months after the end of the month in which the death occurs.