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HMRC internal manual

Inheritance Tax Manual

The settlor: death charge on lifetime transfers chargeable when made

Under IHTA84/S201 (2), where the transfer is not a potentially exempt transfer (IHTM04057) the settlor is not liable under IHTA84/S201 (1)(d) for any extra tax payable because the transferor (i.e. the beneficiary in possession immediately before the transfer) dies within seven years.