IHTM30026 - Liability on death transfers: priorities

IHTA84/S200 contains no provision for determining priorities among the persons liable to tax on the transfer on death.

However IHTA84/S204 (9) contains a priority rule for tax on GWR property treated as part of the death estate ( IHTM30083) under FA 1986 IHTA84/S102(3). Under this section the personal representatives ( IHTM05012) are liable under IHTA84/S200(1)(a) for tax on that property only if it remains unpaid twelve months after the end of the month in which the death occurs.