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Contents

Official guidance
Inheritance Tax Manual

IHTM14000 · Lifetime transfers

  • IHTM14001 · Introduction to lifetime transfers
  • IHTM14011 · Basis of valuation: summary
  • IHTM14012 · Basis of valuation: burden of tax
  • IHTM14013 · Basis of valuation: treatment of expenses
  • IHTM14131 · Specific lifetime exemptions: summary
  • IHTM14132 · Specific lifetime exemptions: order in which exemptions apply
  • IHTM14141 · Annual exemption: summary
  • IHTM14142 · Annual exemption: relievable property
  • IHTM14143 · Annual exemption: multiple transfers
  • IHTM14144 · Annual exemption: roll over provisions
  • IHTM14151 · Schemes to exploit annual exemption: introduction
  • IHTM14152 · Schemes to exploit annual exemption: transfer by sale
  • IHTM14161 · Schemes to exploit annual exemption: transfer of part of a property
  • IHTM14162 · Schemes to exploit annual exemption: transfer of a sum of money
  • IHTM14163 · Schemes to exploit annual exemption: transfer of share equal to a sum of money
  • IHTM14164 · Schemes to exploit annual exemption: transfer of share quantified by loss in value
  • IHTM14165 · Schemes to exploit annual exemption: split proceeds from property on trust for sale
  • IHTM14180 · Small gifts exemption: summary
  • IHTM14191 · Gifts in consideration of marriage or registration of civil partnership: summary
  • IHTM14193 · Gifts made in consideration of marriage or registration of civil partnership: permissible beneficiaries for s.22 purposes
  • IHTM14201 · Gifts in consideration of marriage or registration of civil partnership: Rennell v IRC:
  • IHTM14202 · Gifts in consideration of marriage or registration of civil partnership: Rennell v IRC - gifts by way of settlement
  • IHTM14211 · Gifts in consideration of marriage or registration of civil partnership: IHTA restriction of Rennell - outright gifts and other dispositions
  • IHTM14212 · Gifts in consideration of marriage or registration of civil partnership: IHTA restriction of Rennell - the eventual recipient
  • IHTM14213 · Gifts in consideration of marriage or registration of civil partnership: IHTA restriction of Rennell - S22(4)(b) provisions
  • IHTM14214 · Gifts in consideration of marriage or registration of civil partnership: IHTA restriction of Rennell - payments under covenant
  • IHTM14220 · Gifts in consideration of marriage or civil partnership: relationship with spouse or civil partner exemption
  • IHTM14221 · Gifts in consideration of marriage or civil partnership: termination of IIP in settled property
  • IHTM14231 · Normal expenditure out of income: introduction
  • IHTM14235 · Normal expenditure out of income: life policy linked with an annuity
  • IHTM14236 · Normal expenditure out of income: loans
  • IHTM14241 · Conditions for normal out of income exemption: normal expenditure
  • IHTM14242 · Conditions for normal out of income exemption: pattern of gifts
  • IHTM14243 · Conditions for normal out of income exemption: factors to consider
  • IHTM14244 · Conditions for normal out of income exemption: Case Law - Bennett v IRC
  • IHTM14250 · Conditions for normal out of income exemption: out of income
  • IHTM14251 · Conditions for normal out of income exemption: Case Law - MacDowell
  • IHTM14255 · Conditions for normal out of income exemption: transferor's standard of living
  • IHTM14301 · Gifts with reservation (GWRs): requirements for a GWR
  • IHTM14303 · Gifts with reservation (GWRs): devolution of GWR property
  • IHTM14311 · Gifts with reservation (GWRs): the gift: initial requirements
  • IHTM14312 · Gifts with reservation (GWRs): the gift: the donor
  • IHTM14313 · Gifts with reservation (GWRs): the gift: the property given
  • IHTM14314 · Gifts with reservation (GWRs): the gift: examples of the property given - carve-out arrangements
  • IHTM14315 · Gifts with reservation (GWRs): the gift: defining the gift
  • IHTM14316 · Gifts with reservation (GWRs): the gift: sales for less than full consideration
  • IHTM14317 · Gifts with reservation (GWRs): the gift: interest free loans
  • IHTM14318 · Gifts with reservation (GWRs): the gift: exempt transfers which cannot be GWRs
  • IHTM14319 · Gifts with reservation (GWRs): the gift: exempt transfers which can be GWRs
  • IHTM14331 · Gifts with reservation (GWRs): the reservation: initial requirements
  • IHTM14332 · Gifts with reservation (GWRs): the reservation: possession and enjoyment by the donee
  • IHTM14333 · Gifts with reservation (GWRs): the reservation: exclusion of the donor
  • IHTM14334 · Gifts with reservation (GWRs): the reservation: examples of exclusion of the donor
  • IHTM14335 · Gifts with reservation (GWRs): the reservation: non-exclusion need not be continuous
  • IHTM14336 · Gifts with reservation (GWRs): the reservation: effect of consideration
  • IHTM14337 · Gifts with reservation (GWRs): the reservation: continuation of reasonable commercial arrangements
  • IHTM14338 · Gifts with reservation (GWRs): the reservation: benefit by associated operations
  • IHTM14339 · Gifts with reservation (GWRs): the reservation: benefit to donor's spouse or civil partner
  • IHTM14340 · Gifts with reservation (GWRs): the reservation: when occupation is not a reservation
  • IHTM14341 · Gifts with reservation (GWRs): the reservation: full consideration in cases of land and chattels
  • IHTM14342 · Gifts with reservation (GWRs): the reservation: infirm relative
  • IHTM14343 · Gifts with reservation (GWRs): the reservation: annual exemption not available
  • IHTM14360 · Gifts with reservation (GWRs): the reservation: interests in land
  • IHTM14371 · Gifts with reservation: tracing: introduction
  • IHTM14372 · Gifts with reservation (GWRs): tracing: absolute gifts of cash
  • IHTM14373 · Gifts with reservation (GWRs): tracing: absolute gifts of property other than cash
  • IHTM14374 · Gifts with reservation (GWRs): tracing: supplementary provisions
  • IHTM14391 · Gifts with reservation (GWRs): settled property: introduction
  • IHTM14392 · Gifts with reservation (GWRs): settled property: reversionary interests
  • IHTM14393 · Gifts with reservation (GWRs): settled property: settlement on discretionary trusts
  • IHTM14394 · Gifts with reservation (GWRs): settled property: donor also a trustee
  • IHTM14395 · Gifts with reservation (GWRs): settled property: reasonable commercial arrangements
  • IHTM14396 · Gifts with reservation (GWRs): settled property: charge to inheritance tax on settled property 
  • IHTM14401 · Gifts with reservation (GWRs): tracing settled property: the property comprised in the gift
  • IHTM14402 · Gifts with reservation (GWRs): tracing settled property: if the property ceases to be settled
  • IHTM14403 · Gifts with reservation (GWRs): tracing settled property: settlement by the donee
  • IHTM14421 · Gifts with reservation (GWRs): insurance policies: introduction
  • IHTM14431 · Gifts with reservation (GWRs): insurance policies: general gifts after 18 March 1986
  • IHTM14432 · Gifts with reservation (GWRs): insurance policies: normal out of income exemption on regular premiums
  • IHTM14433 · Gifts with reservation (GWRs): insurance policies: policies made before 18 March 1986
  • IHTM14434 · Gifts with reservation (GWRs): insurance policies: automatic increases in policy value
  • IHTM14435 · Gifts with reservation (GWRs): insurance policies: change in life assured
  • IHTM14440 · Gifts with reservation (GWRs): insurance policies: the property given
  • IHTM14451 · Gifts with reservation (GWRs): the reservation on insurance policies: introduction
  • IHTM14452 · Gifts with reservation (GWRs): the reservation on insurance policies: special rule for policies with linked benefits
  • IHTM14453 · Gifts with reservation (GWRs): the reservation on insurance policies: reservation examples
  • IHTM14502 · The charge to tax: cumulation
  • IHTM14503 · The charge to tax: cumulation with the death estate
  • IHTM14511 · The charge to tax: potentially exempt transfers (PETs): tax treatment of a PET
  • IHTM14512 · The charge to tax: potentially exempt transfers (PETs): tax treatment of a PET followed by death
  • IHTM14513 · The charge to tax: potentially exempt transfers (PETs): cumulation
  • IHTM14514 · The charge to tax: potentially exempt transfers (PETs): cumulating transfers more than seven years before death
  • IHTM14515 · The charge to tax: potentially exempt transfers (PETs): IHT nil rate band
  • IHTM14516 · The charge to tax: potentially exempt transfers (PETs): rate of tax
  • IHTM14517 · The charge to tax: potentially exempt transfers (PETs): taper relief
  • IHTM14518 · The charge to tax: potentially exempt transfers (PETs): fall in value relief
  • IHTM14519 · The charge to tax: potentially exempt transfers (PETs): special rate
  • IHTM14531 · The charge to tax: immediately chargeable transfers: introduction
  • IHTM14532 · The charge to tax: immediately chargeable transfers: value for tax
  • IHTM14533 · The charge to tax: immediately chargeable transfers: cumulation
  • IHTM14534 · The charge to tax: immediately chargeable transfers: rate of tax
  • IHTM14541 · The charge to tax: grossing: when to gross-up
  • IHTM14542 · The charge to tax: grossing: when not to gross-up
  • IHTM14543 · The charge to tax: grossing: partial grossing
  • IHTM14544 · The charge to tax: grossing: the grossing calculation
  • IHTM14545 · The charge to tax: grossing: tax paid after the death of the transferor
  • IHTM14546 · The charge to tax: grossing: settled property
  • IHTM14547 · The charge to tax: grossing: authority for grossing
  • IHTM14550 · The charge to tax: other charges: late reported transfers
  • IHTM14551 · The charge to tax: other charges: death subsequent to the transfer
  • IHTM14571 · The charge to tax: additional charges: introduction
  • IHTM14572 · The charge to tax: additional charges: value for tax
  • IHTM14573 · The charge to tax: additional charges: cumulation
  • IHTM14574 · The charge to tax: additional charges: rate of tax
  • IHTM14575 · The charge to tax: additional charges: taper relief
  • IHTM14576 · The charge to tax: additional charges: the additional tax payable
  • IHTM14577 · The charge to tax: additional charges: the additional tax payable (example 1)
  • IHTM14578 · The charge to tax: additional charges: the additional tax payable (example 2)
  • IHTM14579 · The charge to tax: reliefs: business relief and agricultural relief
  • IHTM14580 · The charge to tax: reliefs: fall in value relief
  • IHTM14590 · The charge to tax: the charge on lifetime transfers: gifts with reservation (GWRs)
  • IHTM14591 · The charge to tax: the charge on lifetime transfers: simultaneous and same day transfers
  • IHTM14592 · The charge to tax: the charge on lifetime transfers: liability for payment of tax
  • IHTM14593 · The charge to tax: the charge on lifetime transfers: grossing-up the values
  • IHTM14595 · The charge to tax: the charge on lifetime transfers: late reported transfers
  • IHTM14611 · Specific lifetime reliefs: taper relief: when the relief applies
  • IHTM14612 · Specific lifetime reliefs: taper relief: quantifying the relief
  • IHTM14613 · Specific lifetime reliefs: taper relief: period of survival
  • IHTM14621 · Specific lifetime reliefs: fall in value relief: introduction
  • IHTM14622 · Specific lifetime reliefs: fall in value relief: form of the relief
  • IHTM14624 · Specific lifetime reliefs: fall in value relief: conditions for relief
  • IHTM14625 · Specific lifetime reliefs: fall in value relief: what is a qualifying sale?
  • IHTM14626 · Specific lifetime reliefs: fall in value relief: what is market value?
  • IHTM14627 · Specific lifetime reliefs: fall in value relief: the claim
  • IHTM14628 · Specific lifetime reliefs: fall in value relief: wasting assets
  • IHTM14629 · Specific lifetime reliefs: fall in value relief: portfolio of assets
  • IHTM14630 · Specific lifetime reliefs: fall in value relief: more than one sale
  • IHTM14631 · Specific lifetime reliefs: fall in value relief: not all of the transferred assets are sold
  • IHTM14641 · Specific lifetime reliefs: shares and securities: adjustments
  • IHTM14642 · Specific lifetime reliefs: shares and securities: capital receipts
  • IHTM14643 · Specific lifetime reliefs: shares and securities: payment of calls
  • IHTM14644 · Specific lifetime reliefs: shares and securities: changes in shareholdings
  • IHTM14645 · Specific lifetime reliefs: shares and securities: transactions of close companies
  • IHTM14661 · Specific lifetime reliefs: interests in land: changes between transfer and death
  • IHTM14662 · Specific lifetime reliefs: interests in land: changes that have reduced the value
  • IHTM14663 · Specific lifetime reliefs: interests in land: changes that have increased the value
  • IHTM14664 · Specific lifetime reliefs: interests in land: compensation
  • IHTM14670 · Specific lifetime reliefs: interests in land: leases
  • IHTM14671 · Specific lifetime reliefs: interests in land: other property
  • IHTM14691 · Specific lifetime reliefs: double charges relief: when double charges arise
  • IHTM14692 · Specific lifetime reliefs: double charges relief: applying the relief
  • IHTM14693 · Specific lifetime reliefs: double charges relief: authority for the relief
  • IHTM14701 · Specific lifetime reliefs: potentially exempt transfers (PETs): when double charges relief arises
  • IHTM14702 · Specific lifetime reliefs: potentially exempt transfers (PETs): partial consideration
  • IHTM14703 · Specific lifetime reliefs: potentially exempt transfers (PETs): assets representing the asset transferred
  • IHTM14704 · Specific lifetime reliefs: potentially exempt transfers (PETs): calculations
  • IHTM14705 · Specific lifetime reliefs: potentially exempt transfers (PETs): Quick Succession Relief (QSR)
  • IHTM14711 · Specific lifetime reliefs: gifts with reservation (GWRs): when double charges relief arises
  • IHTM14712 · Specific lifetime reliefs: gifts with reservation (GWRs): calculations
  • IHTM14713 · Specific lifetime reliefs: gifts with reservation (GWRs): example of calculations 1
  • IHTM14714 · Specific lifetime reliefs: gifts with reservation (GWRs): example of calculations 2
  • IHTM14721 · Specific lifetime reliefs: disallowed debts: when double charges relief arises
  • IHTM14722 · Specific lifetime reliefs: disallowed debts: calculations
  • IHTM14730 · Specific lifetime reliefs: disallowed debts: transfers chargeable when made
  • IHTM14731 · Specific lifetime reliefs: disallowed debts: calculations producing the same amount
  • IHTM14732 · Specific lifetime reliefs: disallowed debts: discretionary trusts
  • IHTM14802 · Omissions: possible omissions of lifetime transfers
  • IHTM14810 · Omissions: omission to exercise a right
  • IHTM14821 · Associated operations: why are the provisions necessary?
  • IHTM14822 · Associated operations: definition
  • IHTM14823 · Associated operations: the objective test
  • IHTM14824 · Associated operations: the subjective test
  • IHTM14825 · Associated operations: additional provisions
  • IHTM14826 · Associated operations: definition of terms
  • IHTM14827 · Associated operations: transfer of value made by associated operations
  • IHTM14828 · Associated operations: restrictions on which operations can be taken into account
  • IHTM14829 · Associated operations: Re Macpherson
  • IHTM14830 · Associated operations: insurance policies
  • IHTM14831 · Associated operations: gifts with reservation (GWRs)
  • IHTM14832 · Associated operations: transfers involving relievable property
  • IHTM14833 · Associated operations: gifts between spouses or civil partners
  • IHTM14834 · Associated operations: sale without immediate payment of the purchase price
  • IHTM14835 · Associated operations: transfer in stages
  • IHTM14836 · Associated operations: successive settlements
  • IHTM14851 · Transfers by close companies: introduction
  • IHTM14852 · Transfers by close companies: transfers of value
  • IHTM14853 · Transfers by close companies: exemptions
  • IHTM14854 · Transfers by close companies: foreign aspects
  • IHTM14855 · Transfers by close companies: alterations in share capital, loan capital or rights
  • IHTM14856 · Transfers by close companies: liability to tax
  • IHTM14871 · Future payments: introduction
  • IHTM14872 · Future payments: calculating the chargeable portion
  • IHTM14873 · Future payments: exemptions
  • IHTM14874 · Future payments: payments outstanding at death
  • IHTM14881 · Dating of dispositions: introduction
  • IHTM14882 · Dating of dispositions: gifts by cheque
  • IHTM14883 · Dating of dispositions: dispositions affecting land
  • IHTM14884 · Dating of dispositions: chattels and corporeal moveables
  • IHTM14885 · Dating of dispositions: choses in action and incorporeal moveables
  • IHTM14890 · Investigation issues: voidable transfers
  • IHTM14900 · Investigation issues: donatio mortis causa (DMC)
  1. Lifetime transfers: contents
  2. Lifetime transfers: the charge to tax: cumulation

IHTM14502 | Lifetime transfers: the charge to tax: cumulation

From HM Revenue & Customs · Inheritance Tax Manual

When you consider how to apply cumulation, there is a variety of factors for you to take into account. Your approach will depend on whether you are looking at

  • the chargeable value of the death estate (IHTM14503)

  • tax directly attributable to a Potentially Exempt Transfer (PET) (IHTM14513)

  • tax on an immediately chargeable transfer (IHTM14533), or

  • additional charges on an immediately chargeable transfer arising on death (IHTM14573)

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