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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 a qualifying interest in possession (IHTM16061) in any property. The limitation is to the extent of those assets. 

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