IHTM30103 | Definition and extent of liability (settled property): beneficiaries
From HM Revenue & Customs · Inheritance Tax Manual
The limitation of liability provisions in apply but only to those persons liable under because they are beneficially entitled to a qualifying interest in possession () in any property. The limitation is to the extent of those assets.
The liability of persons within because they are entitled otherwise than beneficially to a qualifying interest in possession is not limited by .