IHTM30041 - Liability on potentially exempt transfers (PETs): persons liable
Liability for tax on chargeable PETs ( IHTM04057) (other than those on cesser of an interest in possession in settled property ( IHTM30091) is as specified in IHTA84/S199.
Persons liable |
Authority |
| The transferee ( IHTM30051) | IHTA84/S199 (1)(b) |
| Any persons in whom the property is vested ( IHTM30052) | IHTA84/S199 (1)(c) |
| Any beneficiary entitled to an interest in possession ( IHTM30052) | IHTA84/S199 (1)(c) |
| Where property is settled by the transfer, any person for whose benefit any property or income from it is applied ( IHTM30054) | IHTA84/S199 (1)(d) |
| The transferor is not liable but the personal representatives of the transferor ( IHTM30043) are secondarily liable to the extent indicated in IHTA84/S204(8). | IHTA84/S199(2) and S204(8) |
IHTA84/S199(1) specifies that ‘disposition’ ( IHTM04023) includes any omission to exercise a right treated as a disposition under IHTA84/S3(3). Despite this express reference to IHTA84/S3(3), IHTA84/S199(1) should be regarded as applying in similar situations, for example where a transfer of value is treated as made by a disposition under IHTA84/S263 (back-to-back policies ( IHTM20087)).
