Inheritance Tax Act 1984 section 200

Transfer on death

Section 200 identifies who is liable for inheritance tax arising on a chargeable transfer that occurs on a person's death, covering unsettled property, settled property, and property passing to third parties.

  • Personal representatives are liable for tax on unsettled property and on UK land held in a settlement that devolves to them on the deceased's death.
  • Trustees of a settlement are liable for tax on property that was comprised in their settlement immediately before the death.
  • Any person in whom property vests after the death, or who holds a beneficial interest in possession in it, is also liable — but a purchaser (or someone deriving title from a purchaser) escapes this liability unless the property is subject to an HMRC charge.
  • Where settled property is involved, any person for whose benefit the property or its income is applied after the death is additionally liable for the tax attributable to that property.

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