IHTM30062 | Liability on lifetime transfers chargeable when made: persons liable
From HM Revenue & Customs · Inheritance Tax Manual
Where the chargeable transfer is made by a disposition () of the transferor (and the transfer is not a potentially exempt transfer ()), the persons liable for the tax immediately payable are specified in :
The transferor (), who is primarily liable, .
If the tax remains unpaid after the due date (), the following persons are also liable () to a limited extent:
The transferee,
Any person in whom the property is vested,
Where property is settled by the transfer, any person for whose benefit any property or income from it is applied, .
In certain circumstances the spouse or civil partner of the transferor () can be liable, .