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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 PET (IHTM30040) nor on cesser of an interest in possession in settled property (IHTM30090)), there may be two separate IHT charges to consider

  • on the making of the chargeable transfer (IHTM30062)and

  • an additional liability (IHTM30041) on the death of the transferor within seven 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.