IHTM04041 | Transfers on death: the charging provisions
From HM Revenue & Customs · Inheritance Tax Manual
The basic provision governing the tax charge on death is . The charge may be divided into two parts. The subsection provides that on the death of any person (the deceased) tax is charged as if the deceased
had made a transfer of value () immediately before death, and
the value transferred had been equal to the value of the deceased’s estate () immediately before his death.