Section 211 | Burden of tax on death.

(1)Where personal representatives are liable for tax on the value transferred by chargeable transfer made on death, the tax shall be treated as part of the general testamentary and administration expenses of the estate, but only so far as it is attributable to the value of property in the United Kingdom which—

(a)vests in the deceased’s personal representatives, and

(b)was not immediately before the death comprised in a settlement.

(2)Subsection (1) above shall have effect subject to any contrary intention shown by the deceased in his will.

(3)If—^F1

(a)personal representatives pay an amount of tax,^F1

(b)the amount does not fall to be borne as part of the general testamentary and administration expenses of the estate,^F1

(c)property to whose value the tax is attributable is vested in someone other than the personal representatives (“the vestee”), and^F1

(d)the personal representatives cannot recover the amount by deducting it from any sums payable to the vestee out of the estate (whether because there are no sums so payable or because such sums are insufficient or have already been paid without deduction),^F1

the vestee must repay the amount to the personal representatives.

(4)References in this section to tax include references to interest on tax.