‘Transferee’ is shorthand for the wording used in IHTA84/S199 (1)(b) - "any person the value of whose estate is increased by the transfer". Exceptionally it is possible, e.g. by operation of the related property provisions ( IHTM09731), for a person to have the value of their IHT estate to be increased by a transfer even though they do not receive any property from the transferor.
