IHTM30061 | Liability on lifetime transfers chargeable when made: introduction
From HM Revenue & Customs · Inheritance Tax Manual
Where the chargeable transfer is made by a disposition (IHTM04023) of the transferor (and the transfer is neither a potentially exempt transfer (IHTM30041) nor on the ending of a qualifying interest in possession in settled property (IHTM30091)), there may be two separate Inheritance Tax charges to consider
Though the persons liable for both charges are specified in IHTA84/S199, there are important differences between the persons liable for the two charges, so they are dealt with separately.