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HMRC internal manual

Inheritance Tax Manual

Definition and extent of liability (PETs): transferee

‘Transferee’ is shorthand for the wording used in IHTA84/S199 (1)(b) – ‘any person the value of whose estate is increased by the transfer’. Exceptionally it is possible, e.g. by operation of the related property provisions (IHTM09731), for a person to have the value of their Inheritance Tax estate increased by a transfer even though they do not receive any property from the transferor.