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HMRC internal manual

Inheritance Tax Manual

Definition and extent of liability (lifetime transfers chargeable when made): transferor

Under IHTA84/S3 (1) the primary meaning of transferor is a person who makes a disposition (IHTM04023) which reduces the value of their estate. For deemed transfers of value, see IHTA84/S3 (4).

The transferor is primarily liable for the tax payable. IHTA84/S204, limitation of liability section, contains no provisions limiting the liability of the transferor under IHTA84/S199 (1)(a).