IHTM38299 - Notices of Determination (NODs): example E: tax due on a chargeable lifetime transfer or failed Potentially Exempt Transfer

Example E

Inheritance Tax

Notice of Determination

Under s.221, Inheritance Tax Act 1984

To:

The Commissioners of HMRC have determined –

(In relation to

A: the transfer of value ( IHTM04025) made by xxx (“the transferor”) on the occasion of the gift of xxx on xxx to you

B: the death of the transferor on xxx

That –

1. The transfer of value was £xxx on which the tax chargeable is £xxx, of which £xxx remains unpaid, together with interest thereon to date of £xxx.
   
2. As transferee you are liable for the payment of £xxx, with further interest on the unpaid tax until payment.

(NB Remember that, in these cases, you also need to serve NODs on the personal representatives. If the transferee is also a personal representative, one NOD will suffice if you amend para 2 to “As transferee and as personal representative…”)

A caveat ( IHTM38294) applies to Notices issued to liable persons in Open Enquiry cases.