Inheritance Tax Act 1984 section 4

Transfers on death

Section 4 establishes that inheritance tax is charged on a person's death by treating their estate as if it were a transfer of value made immediately before death.

• On death, inheritance tax is charged as though the deceased had made a transfer of value equal to the total value of their estate immediately before death.
• The tax applies to the value of the estate at the moment before death, not to income or capital gains accumulated during the person's lifetime.
• Where two or more people die and the order of their deaths cannot be determined, they are treated for inheritance tax purposes as having died at the same instant.
• This simultaneous death rule for inheritance tax differs from the general succession law presumption that the younger person survived the elder.