Inheritance Tax Act 1984 section 141A

Apportionment of relief under section 141

Section 141A deals with how quick succession relief is shared out across the different components of an estate when part of that estate qualifies for the reduced 36% rate of inheritance tax because of charitable giving.

• Where a later transfer on death qualifies partly for the lower 36% inheritance tax rate (because at least 10% of the estate's baseline amount has been left to charity), the quick succession relief must be apportioned across the estate's components rather than applied as a single lump sum.
• Each qualifying component of the estate receives its share of the quick succession relief in proportion to the tax attributable to that component compared with the total tax on the later transfer as a whole.
• Where parts of an estate are merged into a single component under Schedule 1A, the apportionment applies to that merged component and not to the individual parts within it.
• Any quick succession relief left over after reducing the tax on each qualifying component is applied to reduce the tax on any remaining non-qualifying parts of the estate.