IHTM30062 - 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 potentially exempt transfer (IHTM04057)), the persons liable for the tax immediately payable are specified in IHTA84/S199:

• 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)
• 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.