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HMRC internal manual

Inheritance Tax Manual

Liability on settled property: persons liable

Liability on cesser of an interest in possession on death is governed by IHTA84/S200 and is dealt with in the section on transfers on death (IHTM30023).

Liability on lifetime cesser of an interest in possession and for charges under the discretionary trust regime is governed by IHTA84/S201 as shown in the following table

### Persons liable ### Authority
The trustees (IHTM30101) are primarily liable IHTA84/S201 (1)(a)
If the tax remains unpaid after the due date (IHTA84/S204 (6)(b), the following persons are also liable to a limited extent (IHTM30072).  
any person entitled (whether beneficially or not) to an interest in possession (IHTM16061) in the settled property IHTA84/S201 (1)(b)
any person for whose benefit any of the settled property or income from it is applied at or after the time of the transfer IHTA84/S201(1)(c)
settlor (IHTM30110) if he is alive at the time of the chargeable event and the trustees are for the time being resident outside the United Kingdom. IHTA84/S201(1)(d)