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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Definition and extent of liability (lifetime transfers chargeable when made): spouse or civil partner of transferor

The spouse or civil partner (IHTM11032) of a transferor (IHTM30071) is liable for tax in view of IHTA84/S203 where

  • the transferor is liable as such for any tax
  • the spouse or civil partner (IHTM11032) acquired property from the transferor under a transfer of value (termed the “spouse transfer”) made on or after 17 March 1974 (it is immaterial whether that transfer of value is before or after the transfer of value which occasioned the transferor’s liability or before or after the end of 1984)and

  • they were married to each other or were civil partners of each other at the time of each transfer of value.