Commentary

I11.601 Property subject to Inland Revenue charge

IHT, trusts and estates

I11.601 Property subject to Inland Revenue charge

Division I11.6     Unpaid IHT

For updates affecting this Division please see Part I0 Updates

Inland Revenue charge

I11.601 Property subject to Inland Revenue charge

Where any IHT or interest on it is 'for the time being unpaid', a charge for the amount unpaid is imposed in HMRC's favour on1:

  1.  

    (a)     any property to the value of which the value transferred is wholly or partly attributable, and

  2.  

    (b)     any property comprised in a settlement where the chargeable transfer arises on the making of the settlement or in the course of a settlement under IHTA 1984, ss 43–93 (Pt III).

Where tax is charged under IHTA 1984, Sch A1, property in (a) above includes the UK residential property interest (within the meaning

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