IHTM14705 - PETs: QSR

Double charges relief may be in point where the transferee has died and under their will or intestacy the gifted property is returned to the transferor.

If tax was paid on the transferee’s death, QSR ( IHTM22041) will reduce the tax payable on the subsequent death of the transferor in both calculations ( IHTM14692).

Further, if the PET ( IHTM14511) exceeded the threshold and so itself bears tax on the transferor’s death, QSR will also be due on the transferee’s death by reference to the tax subsequently payable in respect of the PET.