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Where woodlands relief (see I7.402) has been given and IHT is subsequently chargeable¹ on a later disposal (see I7.404) of trees or underwood, it is chargeable on the following amount:

1. Ìý

   •ÌýÌýÌýÌý if the disposal is a sale for full consideration in money or money's worth, on the net proceeds of the sale, and

2. Ìý

   •ÌýÌýÌýÌý in any other case, on the net value, at the time of the disposal, of the trees or underwood (for valuation principles see I8.201 onwards

The IHT is chargeable at the rate which it would have been chargeable on the death if that amount (and any amount on which IHT was previously chargeable² in relation to the death) had been included in the value transferred on the death, and the amount on which the IHT is chargeable had formed the highest part of that value³. Even where the lower rate of tax of IHT would have applied to the estate due to a qualifying legacy to charity (see I4.167), the lower