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HMRC internal manual

Inheritance Tax Manual

Definition and extent of liability (settled property): persons other than trustees

IHTA84/S204 (6) provides that a person liable for tax under IHTA84/S201 otherwise than as trustee of the settlement is liable

  • only if the tax remains unpaid after the due date for payment (IHTM30151) and
  • to no greater extent than they would have been had the value transferred been reduced by the tax unpaid (even though the trustees may have been liable for the grossed up (IHTM26121) amount of the transfer).You can find examples of the operation of IHTA84/S204 (6) at (

IHTM30072) which deal with the operation of the subsection in relation to IHTA84/S199 (1).