There are two rules relating to the charge to IHT where there is more than one chargeable transfer made by the same transferor on the same day.
The first rule does not now very often have any application, but when it does it takes precedence over the second rule. The second rule applies in all cases of chargeable transfers made on the same day except in relation to the deemed transfer on death.
The first rule is that the transfers are treated as having been made in the order which results in the lowest value being chargeable1. The main purpose of this rule is to deal with cases where a transferor makes more than one chargeable lifetime transfer (CLT) on the same day and bears the IHT on at least one of them himself. The value transferred may, because of the grossing up provisions (see I3.523), depend on the order in which they are made. In effect this means that transfers in respect of which the transferor bears the IHT are treated as
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Web page updated on 17 Mar 2025 16:43