Commentary

I10.202A Burden of tax for lifetime gifts

IHT, trusts and estates

I10.202A Burden of tax for lifetime gifts

I10.202A Burden of tax for lifetime gifts

Inter vivos gifts generally

A transferor who makes a chargeable transfer during his lifetime is liable both to pay the IHT in respect of that transfer to HMRC1 (I10.111) and to bear the IHT.

He may agree with the transferee that the transferee shall pay and bear the tax but he remains liable to pay and, if he does pay, he has no charge on the property or other method of recovering the tax except from the transferee under their agreement.

If the transferee has to pay the tax as a liable person2 (but not

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