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HMRC internal manual

Inheritance Tax Manual

Liability on lifetime transfers chargeable when made: introduction

Where the chargeable transfer is made by a disposition (IHTM04023) of the transferor (and the transfer is neither a potentially exempt transfer (IHTM30041) nor on the ending of a qualifying interest in possession in settled property (IHTM30091)), there may be two separate Inheritance Tax charges to consider

  • on the making of the chargeable transfer (IHTM30062)
  • an additional liability (IHTM30041) on the death of the transferor within 7 years.

Though the persons liable for both charges are specified in IHTA84/S199, there are important differences between the persons liable for the two charges, so they are dealt with separately.