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 () of the transferor (and the transfer is neither a potentially exempt transfer () nor on the ending of a qualifying interest in possession in settled property ()), there may be two separate Inheritance Tax charges to consider
on the making of the chargeable transfer ()
an additional liability () on the death of the transferor within 7 years.
Though the persons liable for both charges are specified in , there are important differences between the persons liable for the two charges, so they are dealt with separately.