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Home / Simons-Taxes /IHT, trusts and estates /Part I10 Liability and incidence /Division I10.1 Liability /Liability rules / I10.111D Chargeable lifetime transfers—additional IHT charge—order of liability

I10.111D Chargeable lifetime transfers—additional IHT charge—order of liability

IHT, trusts and estates

There is no order of priority between each of the categories of persons potentially liable, other than for personal representatives.

Primary liability—transferee

HMRC will treat the transferee 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

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E5.607 Corporate members

B3.325 General exclusions—first-year qualifying expenditure

D1.8101 Groups of companies

B3.340A Hire purchase of plant and machinery and similar contracts

B2.218 Surplus business accommodation

C3.1814A CGT exempt assets—qualifying corporate bonds (QCB)

C2.1020 Employment-related securities options and capital gains

I3.750 POAT—introduction to existing arrangements

E8.810 Application for a National Insurance number

C1.106A Annual exempt amount

E4.622 Vans—main rules

I4.562 Sales and mortgages of reversionary interests

I5.251 Absolute entitlement by the life tenant

C2.902 Wasting assets—wasting of allowable expenditure

C2.1231 Leases—deemed premiums

B2.319 Duality of purpose—apportionment of the expenditure

I7.120A BPR and excepted assets

D3.410 Benefits provided by close companies to participators

D1.404B Large company definition for R&D tax relief

C2.1016 Option to subscribe for shares in a company (share warrants)