Commentary

I11.602 Property not subject to Inland Revenue charge

IHT, trusts and estates

I11.602 Property not subject to Inland Revenue charge

I11.602 Property not subject to Inland Revenue charge

Heritable property in Scotland is not subject to the Inland Revenue charge. However, if there is a disposal of such property, any other property representing it is subject to the charge to which the heritable property would otherwise have been subject1. According to HMRC the disposition does not have to be a sale2, though where it is a gift there would appear to be no property representing the original property which could become subject to the charge.

Where the chargeable transfer is made on death, personal or movable property situated in the UK which was beneficially owned by the deceased immediately before his death and vests in his personal representatives is not subject to the

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