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Once the identity of the relevant person (see I7.514A) is established, the rate of tax can be ascertained. This depends upon whether the relevant person is alive or dead at the time of the chargeable event.

The position where he is still alive is as follows and is only relevant if the conditionally exempt transfer was a lifetime transfer made before 18 March 1986 (before PETs were introduced), or was an immediately chargeable transfer made after 17 March 1986. Conditional exemption can only be claimed on PETs after the transferor's death within seven years¹ — see I7.504. The IHT is charged at the half rates appropriate to a lifetime chargeable transfer² made by the relevant person at the time of the chargeable event. Thus the value of the property is notionally added to the cumulative total of chargeable lifetime transfers made by the relevant person within the seven years preceding the chargeable event and charged at the appropriate rate for lifetime chargeable transfers³.

No reduction can be made in respect of any personal