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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 of variation (IoV) 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 an IHTA84/S142(1) IoV

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

You should refer to Technical 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.