IHTM04112 | Heritage property: when a charge to tax arises

From HM Revenue & Customs · Inheritance Tax Manual

Where there has been a conditionally exempt transfer, tax may be subsequently payable on the first occurrence after the transfer (or if the transfer was a potentially exempt transfer, () on the first occurrence after the transferor’s death) of a chargeable event, such as the sale of the asset.

The chargeable events are contained in

  • in connection with properties that are not associated () with each other, and

  • where the event concerns properties that are associated () with each other.

Because of the definition of a conditionally exempt transfer, the charging provisions of and only apply to chargeable events in relation to property conditionally exempted on a transfer on or after 7 April 1976.