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I11.420 The IHT instalment option—overview

Where IHT is payable in respect of certain categories of qualifying property the person liable may elect to pay in ten equal yearly instalments if¹:

1. Ìý

   •ÌýÌýÌýÌý the chargeable transfer was made on death

2. Ìý

   •ÌýÌýÌýÌý the IHT is borne by the person benefiting from the transfer, or

3. Ìý

   •ÌýÌýÌýÌý the chargeable property is settled property remaining in the settlement after the chargeable event.

The right to pay by instalments relates to the IHT 'attributable' to qualifying property². Where the value transferred by a chargeable transfer (usually a transfer on death) is determined by reference to the values of more than one property, the IHT on the value transferred is attributed to the respective values in the proportions which they bear to their aggregate. This is subject to IHTA 1984, s 54B(3) (the rarely used special rate anti-avoidance provision – see I3.526), and to any provision reducing the amount of tax attributable to the value of any particular property³ (for example BPR or APR).