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HMRC internal manual

Inheritance Tax Manual

Liability on settled property: persons liable

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

Liability on the ending during lifetime of a qualifying interest in possession and for charges under the relevant property regime is governed by IHTA84/S201 as follows:


### 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 a qualifying 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 (IHTM30111) 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)