IHTM22042 - Quick succession relief: when the relief applies

For tax on the deceased’s death estate to be reduced by quick succession relief (QSR) (IHTM22041) there must be

  • an earlier chargeable transfer (IHTM04027)
  • within five years of the death
  • on which tax was (or becomes) payable, and
  • the chargeable transfer must have increased the deceased’s estate.

»Ê¹ÚÌåÓýapp earlier chargeable transfer can be

  • on death
  • a lifetime transfer chargeable when made (IHTM04067)
  • a failed potentially exempt transfer (IHTM0457), or
  • of settled property (IHTM16000) whether held on interest in possession (IHTM16061) or discretionary trusts.

Example

Manish died in March 2008 leaving an estate of £350,000. By Will his whole estate passed to a child, Dinesh. Tax of £20,000 was paid.

Dinesh dies in 2010. QSR is due on Dinesh’s death if his estate is also taxable.

»Ê¹ÚÌåÓýapp assets the deceased received under the earlier transfer need not be included in the deceased’s death estate for the QSR to be due. But if a comparison of the deceased’s free estate (IHTM04029) and the earlier transfer suggests there may be undisclosed lifetime gifts you must consider whether an enquiry is appropriate.

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