Where the transferor or trustees of a settlement leave tax unpaid, then the other persons potentially liable in relation to that transfer (see ¶1925) become liable. Where the value transferred is partly attributable to the tax payable on it (i.e. the reduction in value of the person’s estate is the value transferred plus the tax payable on it), then those other persons will be liable to no greater extent than they would have been had the value transferred been reduced by the tax remaining unpaid. Liability may also be restricted according to the nature of the person’s interest therein as mentioned below.

Example

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