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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers chargeable when made: previous legislation and lifetime transfers

Under the earlier legislation the only condition is that the tax attributable to the qualifying property was borne by the person benefiting from the transfer.

However instalments were of course not available if the property concerned had been sold by the transferee (IHTM30244). (The FA 1986 amendment to IHTA84/S227 covered only the tax payable on a potentially exempt transfer (PET) (IHTM04057).)