IHTM30102 - Definition and extent of liability (settled property): persons other than trustees

IHTA84/S204 (6) provides that a person liable for tax under IHTA84/S201 otherwise than as trustee of the settlement is liable

• only if the tax remains unpaid after the due date for payment ( IHTM30151) and
• to no greater extent than they would have been had the value transferred been reduced by the tax unpaid (even though the trustees may have been liable for the grossed up ( IHTM26121) amount of the transfer).

You can find examples of the operation of IHTA84/S204 (6) at ( IHTM30072) which deal with the operation of the subsection in relation to IHTA84/S199 (1).