IHT on the estate of a deceased person — the general rule

Where a PR is liable to IHT on the estate of a deceased person, that IHT is treated as part of the general testamentary and administrative expenses of the estate (ie so that the burden of the tax falls on the residue of the estate) but only to the extent that:

1. •

   the IHT is attributable to assets situated in the UK

2. •

   those assets vest in the PR, and

3. •

   those assets were not comprised in a settlement immediately before the death

IHTA