APR on death following a lifetime gift

When an individual has made transfers within seven years of his death:

1. •

   an additional charge will be levied at the time of his death if the transfer was a chargeable lifetime transfer (CLT).

   If the amount of the transfer was reduced by APR, the additional charge to tax is levied on the reduced amount.

2. •

   inheritance tax will be charged for the first time if the transfer during his lifetime was a potentially exempt transfer (PET).

   The amount of the transfer is reduced by APR before the charge is levied, but only if the transfer qualified for APR at the time of the PET.

See the Agricultural property relief (APR) guidance note.

However, in both