Commentary

I7.514A The relevant person

IHT, trusts and estates

I7.514A The relevant person

I7.514A The relevant person

The rate of IHT chargeable is determined by reference to the circumstances of the 'relevant person', who is not necessarily the person who made the last conditionally exempt transfer before the chargeable event. He is not the person who is liable for the tax1.

Three rules apply:

  1.  

    (a)     if there has been only one conditionally exempt transfer of the property before the chargeable event, the person who made it is the relevant person

  2.  

    (b)     if there has been more than one conditionally exempt transfer before the chargeable event and:

    1.  

      –     the last one was made more than

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