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HMRC internal manual

Inheritance Tax Manual

End of instalment option: chargeable transfers otherwise than on death

The following special provisions apply where the chargeable transfer on which the tax is being paid by instalments was made otherwise than on death, in addition to the general rules (IHTM30321).

Instalments under IHTA84/S227 (1)(b) - the tax being borne by the person benefiting from the transfer

The unpaid tax becomes immediately payable on any further chargeable transfer (otherwise than on death) in which the value transferred is wholly or partly attributable to the property concerned. However if the transferee (IHTM30244) dies before the transferor, this does not apply to tax within IHTA84/S227 (1) (a). 

Instalments under IHTA84/S227 (1)(c) - charge under Part III IHTA, the property remaining in the settlement

The unpaid tax becomes immediately payable when the property concerned ceases to be comprised in the settlement (IHTM30290).

The meaning of ‘sold’ (IHTM30322) and the rules relating to underwriting interests (IHTM30323) are the same as for transfers on death.