This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Inheritance Tax Manual

Relevant property trusts: practice with IHT100


Lifetime Transfer Teams in Nottingham deal with all settlement charges. (IHTM42070)

The teams also deal with chargeable lifetime transfers (IHTM42251). If the settlor has died then lifetime issues are handled by the death caseworker

  • Structure of the IHT100 is explained at section 10 of this manual from IHTM10650.
  • General investigation issues are set out from IHTM10677.

Due dates

  • Due date for payment of tax is explained at IHTM30154 
  • Due date for delivery of the form is one year after the end of the month in which the chargeable event took place. (IHTM10803)
  • Where an account is delivered late and there is tax to pay, you must consider a penalty. Appropriate amounts and procedures are explained from IHTM36023.


  • Lifetime transfers: Pink lifetime file. 
  • Lifetime transfers, transferor subsequently dies: White death file. (Any existing lifetime file should be amalgamated with the death file and cancelled/converted.)
  • TYA and proportionate charges: Blue settlement file. To save costs, these events are often dealt with at the existing lifetime or death file if the event is non-taxpaying.

When appropriate, ask FACET to create or amend these files on Entg15.

Risk Assessment

All IHT100 accounts are considered initially by non-death Risk Assessors. They will arrange for any relevant papers to be obtained, and decide whether the case should be sent for enquiry in CG, or provide a direction for the action to be taken by PC&S.

Compliance investigation

Main investigation issues are

  • Accumulated income and IHTA84/S66 (2) relief (IHTM42088)
  • Unnatural growth of trust fund (how has this occurred, have there been further additions)
  • BR, AR and exemptions
  • Gaps in the history of the settlement (events not previously notified)
  • Residential property (is it relevant property, or does an interest in possession exist)
  • Non-delivery of accounts
  • Excluded property claims and unusual deductions
  • Activities reported from other HMRC offices