IHTM14541 - Grossing: when to
gross-up
Grossing applies when the tax on the chargeable transfer is
borne by the transferor. (
IHTM14593)
You should gross-up the value transferred if
- the account or correspondence states that
the transferor is to bear the tax
- at the time of the transfer the transferor
enters into a binding agreement to pay the tax
- after the transfer, the transferor pays
tax (even an instalment) direct to HMRC,
or
- the tax is paid from the
transferor’s death estate (
IHTM14543).
When grossing applies in one of these situations,
do not allow instalments [under the provisions of
IHTA84/S227 (1)(b)].