Commentary

I10.117 More than one person liable

IHT, trusts and estates

I10.117 More than one person liable

I10.117 More than one person liable

Where two or more persons are liable for the same IHT then each person can be made liable for the whole of the tax, although HMRC cannot recover more than the whole1. A person so liable will be able to recover the IHT paid where, under the rules of incidence of IHT, someone else is ultimately to bear the burden of the tax2. The trustees of a fund over which the deceased had, and exercised by will, a general power of appointment are liable for the tax attributable to the property3. The personal representatives

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