Inheritance Tax Act 1984 section 199

Dispositions by transferor

Section 199 identifies who is liable for inheritance tax when a transferor makes a chargeable transfer by way of a disposition, including deemed dispositions arising from an omission to act.

• Liability falls on the transferor, anyone whose estate increases as a result, anyone in whom the property vests, and anyone who benefits from property placed into a settlement by the transfer.
• Where a potentially exempt transfer becomes chargeable on death, or additional tax arises on a lifetime transfer because the transferor dies within seven years, the transferor's personal representatives step into the transferor's shoes as the liable person.
• A purchaser of the property (or anyone deriving title from that purchaser) is not liable for tax attributable to the property unless an Inland Revenue charge applies to it.
• Anyone who takes possession of, intermeddles with, or manages the property — thereby becoming liable as executor, trustee, or on behalf of a person lacking full legal capacity — is treated as a person in whom the property is vested, and references to property include anything directly or indirectly representing it.