»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýapp right to reimbursement is most likely to arise in connection with a guarantee debt (IHTM28354). But it may also arise in relation to, for example, a lessee who has assigned a lease - in which case the lessee would be entitled to reimbursement from the assignee. And in Re Latham [1962] Ch 616 a debt, being Estate Duty payable on the death of a first life tenant that remained unpaid, was held not to be a permissible deduction from the estate of a second life tenant. This was on the basis that the second life tenant’s free estate had a right to reimbursement from the capital of the trust fund of which he was tenant for life.

»Ê¹ÚÌåÓýapp right to reimbursement can also arise in connection with lifetime transfers. If the deceased makes an immediately chargeable transfer which gives rise to a tax liability and the tax payable is deducted from the estate then you should call for the lifetime file and consult with Technical.