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HMRC internal manual

Inheritance Tax Manual

How many variations can be attempted?: second variation affecting the same property

Our view that an instrument does not fall within IHTA84/S142 if it further redirects any item or part of an item that has already been redirected was upheld by Knox J in Russell v IRC (1988) STC 195. Accordingly

  • where there has been an IoV accepted as within IHTA84/S142 (1)
  • there cannot be a IHTA84/S142 (1) IoV

    • in relation to any part of the same property
    • in connection with the same death.

You should refer to TG any case where this appears to apply, or any case in which there is an IoV and a disclaimer (whatever the order) affecting the same property on the same death.