HMRC internal manual

Inheritance Tax Manual

IHTM30243 - Transfers and other events on or after 17 March 1987: settled property

You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.


  • the property is settled by the transfer
  • the tax is payable by the trustees of the settlement


  • the tax is borne by the trust fund

the tax is regarded as borne by the person(s) benefiting from the transfer for the purposes of IHTA84/S227(1)(b).  This applies whether the trust is a relevant property trust (IHTM42161) or one in which there is a qualifying interest in possession (IHTM16061).