If the settlor dies seven years of transferring assets to the settlement the trustees could be liable for additional IHT1, and where the transfer was a PET none of the tax is payable unless and until the settlor dies within seven years of the transfer.
For the factors affecting the amount of tax charged see I3.511–I3.512, I3.531–I3.533.
One factor of special note is that if a lifetime transfer into settlement was of property which then qualified for BPR or APR, the relief may be clawed back as a result of
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