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HMRC internal manual

Inheritance Tax Manual

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


  • 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).