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IHTM30041 | Liability on potentially exempt transfers (PETs): persons liable

From HM Revenue & Customs · Inheritance Tax Manual

Liability for tax on chargeable potentially exempt transfers (PETs) (), apart from those on the ending of a qualifying interest in possession in settled property (), is specified in . The persons liable are

  • The transferee (),

  • Any persons in whom the property is vested (),

  • Any beneficiary entitled to an interest in possession (),

  • Where property is settled by the transfer, any person for whose benefit any property or income from it is applied (),

  • The transferor is not liable but the personal representatives of the transferor () are secondarily liable to the extent indicated in , and S204(8).

specifies that ‘disposition’ () includes any omission to exercise a right treated as a disposition under . Despite this express reference to , should be regarded as applying in similar situations, for example where a transfer of value is treated as made by a disposition under (back-to-back policies ()).