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HMRC internal manual

Inheritance Tax Manual

Liability in special cases: heritage property

Where property has been conditionally exempted and tax later becomes payable under IHTA84/S32 or IHTA84/S32 A or Sch 5 Paras 1 or 3 because

  • the property is disposed of
  • the statutory undertaking is not observed
  • the beneficiary diesthe persons liable are specified in IHTA84/S207. They are

  • on disposal by sale, gift or otherwise apart from on death - the person by whom or for whose benefit the property is disposed of (includes the beneficial owner or a trustee or other person who makes a disposal in a fiduciary capacity)
  • on breach of the undertaking or on death - the person who would be entitled to receive (whether for their own benefit or not) the proceeds of sale or any income arising from them if the property were sold at the time of the breach or immediately after the death.