IHTM22080 - Quantifying increase at deceased's estate: PQSR

The basic situation when potential quick succession relief occurs is when

• lifetime gift by A to B
• death of B within the five year QSR period
• later death of A within seven years of the gift, on which tax is then payable.

As the extent of the PQSR depends on the actual tax paid, you must wait to see what is paid on the transferor's death before giving any PQSR on the transferee's death. If tax is then paid, you may give QSR ( IHTM22041) in the normal way. Though the tax paid on the transfer is triggered by the transferor's death, it is due in respect of the earlier gift and treated as having been paid at that time.

Refer to TG for directions if

• the donor's Will provides for the tax on the gift to be paid out of their estate, or
• the donee leaves their estate (or part of it) to the donor.