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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Liability on lifetime transfers chargeable when made: persons liable

Where the chargeable transfer is made by a disposition (IHTM04023) of the transferor (and the transfer is not a PET (IHTM04057)), the persons liable for the tax immediately payable are specified in IHTA84/S199 as shown in the following table.

### Persons liable ### Authority
The transferor (IHTM30071), who is primarily liable IHTA84/S199 (1)(a)
If the tax remains unpaid after the due date (IHTA84/S204 (6)(a)), the following persons are also liable (IHTM30072) to a limited extent  
the transferee IHTA84/S199 (1)(b)
any person in whom the property is vested IHTA84/S199 (1)(c)
and where property is settled by the transfer, any person for whose benefit any property or income from it is applied. IHTA84/S199 (1)(d)
In certain circumstances the spouse or civil partner of the transferor (IHTM30073) can be liable. IHTA84/S203