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HMRC internal manual

Inheritance Tax Manual

Definition and extent of liability (settled property): beneficiaries

The limitation of liability provisions in IHTA84/S204 (3) apply but only to those persons liable under IHTA84/S201 (1)(b) because they are beneficially entitled to an interest in possession (IHTM16061) in any property. The limitation is to the extent of that property.

The liability of persons within IHTA84/S201 (1)(b) because they are entitled otherwise than beneficially to an interest in possession is not limited by IHTA84/S204 (3).