IHTM30244 | Transfers and other events on or after 17 March 1987: the transferee
From HM Revenue & Customs · Inheritance Tax Manual
‘The transferee’ is defined (by for the purposes of the section as a whole) as the person who became the owner of the qualifying property on the transfer or, where the transfer was into a relevant property trust (), the trustees of the settlement. In view of , when the transfer was into a qualifying interest in possession trust (), the life tenant is the transferee.