IHTM30353 | Rates of interest: the higher and lower rates before 16 December 1986
From HM Revenue & Customs · Inheritance Tax Manual
In the period prior to 16 December 1986 there were two rates of interest:
The lower interest rate (the death rate), was appropriate for:
transfers on death
potentially exempt transfers (failed PETs (IHTM04057))
tax charged under the gifts with reservation (IHTM04071) provisions (treated either as part of the transfer on death or as potentially exempt transfers (failed PETs))
the Additional Charges (IHTM14571) on an immediately chargeable transfer when the transferor dies within seven years of the transfer
any tax for which, by virtue of IHTA84/S206, only a political party was liable
any additional tax payable when the settlor dies after an occasion of charge under Chapter III Part III
tax repayable under IHTA84/S147 (2)
The higher rate was charged in any other case. The higher rate was expressly applied by IHTA84/S236 (3) to tax repayable on a claim under IHTA84/S146 (2) (which concerns Orders under IHTA84/S10 Inheritance (PFD) Act 1975) and IHTA84/S150 (voidable transfers (IHTM14890)). The higher rate was also expressly applied, by IHTA84/S236 (4), to tax charged by virtue of IHTA84/S147 (4) (legitim (IHTM35211)).
Seek advice from Technical if you need details of these statutory rates.