IHTM30102 - Definition and extent
of liability (settled property): persons other than trustees
IHTA84/S204 (6) provides that a person liable for tax under
IHTA84/S201 otherwise than as trustee of the settlement is
liable
- only if the tax remains unpaid after the
due date for payment (
IHTM30151) and
- to no greater extent than they would have
been had the value transferred been reduced by the tax unpaid (even
though the trustees may have been liable for the grossed up (
IHTM26121) amount of the
transfer).
You can find examples of the operation of IHTA84/S204 (6) at (
IHTM30072) which deal with the
operation of the subsection in relation to IHTA84/S199 (1).