Inheritance Tax Act 1984 section 164

Transferor's expenses

Section 164 sets out how expenses incurred by the transferor in making a transfer of value are treated when calculating the value transferred for inheritance tax purposes.

• Expenses incurred by the transferor in making a transfer of value are treated differently depending on who bears the cost
• If the transferor bears the expenses, they are ignored when calculating the value transferred
• If a beneficiary of the transfer bears the expenses, they reduce the value transferred
• The transferor's own liability for inheritance tax is not treated as an expense under this rule