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HMRC internal manual

Inheritance Tax Manual

Definition and extent of liability: personal representatives

Under IHTA84/S272 the term ‘personal representatives’ (IHTM05012) includes

  • any person by whom, or on whose behalf, an application is made for a grant (IHTM05001) or reseal in the United Kingdom
  • any such person as is mentioned in IHTA84/S199 (4)(a) - broadly an executor de son tort or constructive trustee.


In Scottish law ‘personal representatives’ has no precise meaning.  It should be regarded as comprising in Scotland those persons who would answer the description in English law (including the extension by IHTA84/S272). Any question of whether a Judicial Factor is included in the term should be referred to Technical in Edinburgh.