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HMRC internal manual

Inheritance Tax Manual

Transfers and other events on or after 17 March 1987: the transferee

‘The transferee’ is defined (by IHTA84/S227(1B) for the purposes of the section as a whole) as the person who became the owner of the qualifying property on the transfer or, where the transfer was into a relevant property trust (IHTM16042), the trustees of the settlement. In view of IHTA84/S 49 (1), when the transfer was into a qualifying interest in possession trust (IHTM16061), the life tenant is the transferee.