The Inheritance Tax Act (IHTA) 1984 makes a clear distinction between liability and accountability (IHTM10801). In this context liability means liability for the payment of tax.

IHTA Part VII, beginning at IHTA84/S199, states who is liable to pay tax and the exceptions from, and limitations on, liability.

Under IHTA84/S205, except as otherwise provided, where under the IHTA two or more persons are liable for the same tax, each of them is liable for the whole.

There are three main categories of liability to pay tax

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