IHTM14721 - Disallowed debts: when double charges relief arises

You can allow relief under the Inheritance Tax (Double Charges Relief) Regulations 1987 (SI 1987/1130) Reg.6 in cases where the deceased made a failed PET ( IHTM14511) or immediately chargeable lifetime transfer ( IHTM04067) which

  • increased the estate of the transferee

or

  • resulted in property becoming comprised in a settlement,

and before their death the deceased incurred a liability to

  • the transferee

or

  • the trustees of the settlement

and

  • which is a liability subject to abatement under FA86/S103. ( IHTM28361)