IHTM14593 - How lifetime transfers are brought into the charge for tax: grossing-up the values

Sometimes you need to calculate the gross value of the transfer, including the tax burden if it is payable by the transferor. The authority behind this reflects that the tax burden effectively increases the loss to the transferor’s estate. ( IHTM14547)

Be alert for instances where the transferor pays the tax. You can find details of such instances in the earlier immediately chargeable transfers section ( IHTM14541). Also note that instalments may not apply to these situations.

Generally, grossing only applies to immediately chargeable transfers and not to failed PETs ( IHTM04057) (unless the transferor is obliged to pay the tax) or additional charges ( IHTM14572).

Calculate the grossed-up value as you would for grossing-up specific legacies ( IHTM26011) before arriving at exempt residue on a death estate. Where the tax rate is 40% you can use the computerised grossing calculator.

You will have to prepare the calculations manually however where the tax rate is lower than 40%. ( IHTM14544)