Where an election is made to pay tax by instalments, and the property in question is sold before the end of the instalment period, the tax unpaid at the date of the sale, together with any accrued interest, becomes payable forthwith (IHTA 1984, s. 227(4)). Where part of the property is sold, a proportionate part of the tax becomes payable.

Tax similarly becomes payable forthwith in any of the following circumstances (s. 227(5)):

where, following an election made on a lifetime transfer on which the donee bore the tax, the donee makes a chargeable transfer of value wholly or partly attributable to the property in question (other than a transfer on death);

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