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HMRC internal manual

Inheritance Tax Manual

How many variations can be attempted?: introduction

The published guidelines (IHTM35021) set out the following broad framework in which to consider when several variations can be made.  This is that

  • an election which is validly made is irrevocable
  • an instrument will not fall within IHTA84/S142 if it further redirects any item or any part of an item that has already been redirected under an earlier instrument
  • to avoid any uncertainty variations covering a number of items should be made in one instrument
  • multiple instruments which lie outside these guidelines will have to be considered individually to determine whether or not they qualify.