I3.531 CLTs within seven years of death—cumulation and tax rates
On a person's death additional IHT may become payable in respect of any chargeable lifetime transfer (CLT) made within seven years of death (see I3.319 for further information on these transfers).
Such a transfer may have already have given rise to an IHT charge during the transferor's life as described in I3.521, but the IHT charge on the transfer must be recalculated taking into account new factors that can be a consequence of the death, such as the IHT rates for transfers on death becoming applicable or there being an increased relevant cumulative total of previous chargeable transfers (see below).
If the result is a tax charge of a greater amount than that which has already been paid the additional tax becomes payable1 six months after the end of the month in which the transferor died2, and is primarily payable by the transferee3.
The IHT rate used to recalculate the IHT on a CLT is the same as for a potentially exempt transfer (PET). It is related to how long the transferor has survived the transfer. It is the same as the death rate if he has survived it by three