Liability on potentially exempt transfers (PETs): persons liable
Liability for tax on chargeable potentially exempt transfers (PETs) (IHTM04057), apart from those on the ending of a qualifying interest in possession in settled property (IHTM30091), is 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)).