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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Pre-owned assets: avoidance of double charges: introduction

There are a number of circumstances in which a double charge to tax may arise. This may be a double charge to the same tax, or a separate charge to both income tax and Inheritance Tax arising on the same occasion. Some of the double charges come about as taxpayers seek to unravel Inheritance Tax planning so as to avoid the pre-owned assets charge. So FA04/Sch15 contains two specific provisions to deal with double income tax charges. The power contained in FA86/S104 allows the Board to make regulations to relieve double charges to Inheritance Tax.