The liability of the transferor's personal representatives (IHTM05012) is a sensitive area of the legislation. You must alert the personal representatives at an early stage where recourse to them might occur. In cases where the transferee (IHTM30051) is not resident in the UK we are likely to be aware of that fact from the replies on the schedule IHT403, but nevertheless we should still warn the personal representatives of their potential liability, if the transferee and any other persons who may be liable under IHTA84/S199 (1) do not pay.

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