IHTM14541 | Lifetime transfers: the charge to tax: grossing: when to gross-up

From HM Revenue & Customs · Inheritance Tax Manual

Grossing applies when the tax on the chargeable transfer is borne by the transferor. ()

You should gross up the value transferred if

  • the account or correspondence states that the transferor is to bear the tax

  • at the time of the transfer the transferor enters into a binding agreement to pay the tax

  • after the transfer, the transferor pays tax (even an instalment) direct to HMRC, or

  • the tax is paid from the transferor’s death estate ().

All these situations are caught by . You should not allow instalments in cases where arrangements of this kind are revealed.