Where woodland relief (
IHTM04371) is available, the person
liable for the tax may elect to exclude the value of the trees or
underwood (but not the land itself) from the value transferred by
the chargeable transfer on the deceased’s death and instead
pay tax when the trees are disposed of, e.g. by sale or gift, other
than to the disposer’s spouse or civil partner (
IHTM11032).
This deferred charge (
IHTM04122) on disposal runs only until
the land on which the trees were growing forms part of a chargeable
transfer (
IHTM04027) on another death. If there
has not been a disposal between the two deaths, the deferred charge
by reference to the earlier death is extinguished (without any tax
becoming due) by the chargeable transfer on the later death.
