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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
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Liability on potentially exempt transfers (PETs): persons liable

Liability for tax on chargeable PETs (IHTM04057) (other than those on cesser of an interest in possession in settled property (IHTM30091) is as specified in IHTA84/S199.

### Persons liable ### Authority
   
The transferee (IHTM30051) IHTA84/S199 (1)(b)
Any persons in whom the property is vested (IHTM30052) IHTA84/S199 (1)(c)
Any beneficiary entitled to an interest in possession (IHTM30052) IHTA84/S199 (1)(c)
Where property is settled by the transfer, any person for whose benefit any property or income from it is applied (IHTM30054) IHTA84/S199 (1)(d)
The transferor is not liable but the personal representatives of the transferor (IHTM30043) are secondarily liable to the extent indicated in IHTA84/S204(8). IHTA84/S199(2) and S204(8)

IHTA84/S199(1) specifies that ‘disposition’ (IHTM04023) includes any omission to exercise a right treated as a disposition under IHTA84/S3(3). Despite this express reference to IHTA84/S3(3), IHTA84/S199(1) should be regarded as applying in similar situations, for example where a transfer of value is treated as made by a disposition under IHTA84/S263 (back-to-back policies (IHTM20087)).