The rate chargeable on the disposal is intended to be that which would have applied had the property not been left out of account on death. Thus the amount chargeable is treated as the top slice of the deceased's estate (including any amount which has previously become chargeable under IHTA 1984, s. 126) and tax is payable at the full rate applicable at the time of the disposal (s. 128; Sch. 2, para. 4).
Andrew, who has made lifetime transfers amounting to £80,000, dies on 1 March 2013, leaving a chargeable estate valued at £300,000, plus woodlands which are left out of account. The woodlands are left to Graham and Craig.