There is no order of priority between each of the categories of persons potentially liable, other than for personal representatives who are not primarily liable.
Primary liability—transferee
HMRC will treat the transferee (including transferee trustees) as primarily liable1.
Primary liability—others under IHTA 1984, ss 199(1)(c), 199(1)(d)
If HMRC have any issues collecting the IHT from the transferee then they will consider attaching the liability to any person
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