The primary liability for tax chargeable on a lifetime transfer at the time when it is made rests with the transferor, or his personal representatives. All the other persons mentioned in ¶183-075 above are liable only if the tax remains unpaid after it ought to have been paid (IHTA 1984, s. 204(6)). Where tax has been calculated on the grossed-up equivalent of a net gift, persons other than the transferor are liable only in respect of tax on the ungrossed amount. This is reasonable, acknowledging that if the transferor fails to pay the tax, the loss to his estate is not so great.
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