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I11.440 IHT—property subject to Inland Revenue charge

Where any IHT or interest on it is 'for the time being unpaid', a charge for the amount unpaid is imposed in HMRC's favour on¹:

1. Ìý

   (a)ÌýÌýÌýÌý any property to the value of which the value transferred is wholly or partly attributable, and

2. Ìý

   (b)ÌýÌýÌýÌý any property comprised in a settlement where the chargeable transfer arises on the making of the settlement or in the course of a settlement under IHTA 1984, ss 43–93 (Pt III).

Where tax is charged under IHTA 1984, Sch A1, property in (a) above includes the UK residential property interest (within the meaning of that Schedule) to which the charge to tax relates².

Although the Inland Revenue is now called HMRC, the charge continues to be called the Inland Revenue charge.

Also, property which at the death of the transferor represents property, or an interest in property, to which the value transferred by a potentially exempt transfer made by him was wholly or partly attributable, is