IHTM30102 | Definition and extent of liability (settled property): persons other than trustees
From HM Revenue & Customs · Inheritance Tax Manual
provides that a person liable for tax under other than as trustee of the settlement is liable
only if the tax remains unpaid after the due date for payment () and
to no greater extent than they would have been had the value transferred been reduced by the tax unpaid (even though the trustees may have been liable for the grossed up () amount of the transfer).
You can find examples of the operation of at which deal with how this subsection works in relation to .