Advanced Taxation (UK) · Inheritance tax: administration and payment, including the instalment option

Due Dates and Liability for Payment of IHT on Lifetime Transfers and Death

Updated 11 October 2026 · Fact-checked

Tax on a lifetime chargeable transfer is due on the later of 30 April after the end of the tax year of transfer and six months after the end of the month of transfer. Death tax is due six months after the end of the month of death. Donor and trustees are liable on a CLT; personal representatives on the estate.

Understand Due Dates and Liability for Payment of IHT

Inheritance tax (IHT) is only useful to a client if you can say when the cash must leave and whose cash it is. ATX-UK questions often ask you to advise on both. The rules are mechanical, so they are easy marks if you learn them.

Due date. For a lifetime chargeable transfer (CLT), tax is due on the later of two dates: 30 April after the end of the tax year in which the transfer is made, and six months after the end of the month of transfer. For a transfer from 6 April to 30 September, the later date is 30 April in the following tax year. For a transfer from 1 October to 5 April, the later date is six months after the end of the month of transfer. For tax on death, whether on the death estate or on a failed PET, the tax is due six months after the end of the month of death. Always check the exact month before you count.

Who is liable. Liability is split into primary and secondary. The person with primary liability is the first one HMRC looks to. The people with secondary liability only pay if the primary person does not.

On a CLT, the donor (transferor) and the trustees of the trust that receives the gift are both primarily liable for the lifetime tax. In practice the trustees often pay by agreement. If the trustees pay, there is no gross up. Tax is the 20% lifetime rate on the excess of the gift over the available nil rate band. If the donor pays, the tax is itself a further reduction in the donor's estate, so the net gift is grossed up. Gross up the excess over the nil rate band at 20/80 (that is, ×100/80). Where the donor dies within seven years of the CLT, additional tax at the death rate of 40% may be due, less the lifetime tax already paid and after any taper relief. The trustees are primarily liable for that extra tax. The donor's personal representatives are secondarily liable, and only to the extent the trustees do not pay the additional tax.

On a PET that fails because the donor dies within seven years, the donee is primarily liable for the tax. The tax is due six months after the end of the month of death. The donor's personal representatives are secondarily liable, and only to the extent the tax is still unpaid because the donee has not paid it. In that case the tax falls on the donor's estate. Taper relief reduces the tax where the gift was made more than three years before death.

On the death estate, the personal representatives are primarily liable for tax on the assets they control. Tax on assets that pass outside the will, such as trust assets, can fall on the trustees. Beneficiaries or recipients can have secondary liability to the extent of the assets they receive.

Key rules to remember

Due date: lifetime chargeable transfer (April to September): Later of 30 April after the end of the tax year of transfer and 6 months after the end of the month of transfer. For a transfer made 6 April to 30 September this is 30 April in the next tax year; For example, a CLT on 10 June 2025 has tax due on 30 April 2026.
Due date: lifetime chargeable transfer (October to April): Transfer made 1 October to 5 April: tax due 6 months after the end of the month of transfer (this is the later date); For example, a CLT on 15 November 2025 has tax due on 31 May 2026. A CLT on 10 March 2026 has tax due on 30 September 2026.
Due date: tax on death: Tax due 6 months after the end of the month of death; Applies to the death estate, to tax on a failed PET and to additional tax on a CLT made within seven years of death.
Liability: lifetime CLT: Donor and trustees are both primarily liable for the lifetime tax (trustees often pay by agreement); If the donor pays, gross up the excess over the nil rate band at 20/80. If the trustees pay, no gross up. The lifetime rate is 20% on the excess over the nil rate band of £325,000.
Liability: failed PET and additional tax on CLT: Failed PET: donee primarily liable; personal representatives secondarily liable, only to the extent the tax is unpaid after the donee fails to pay (the donor's estate then bears it). Additional tax on CLT: trustees primarily liable; personal representatives secondarily liable, only to the extent the trustees do not pay; Death rate is 40% on the excess over the nil rate band, reduced by taper relief where the gift was made more than three years before death.
Primary liability: death estate: Personal representatives; Secondary liability can fall on those who receive the property.
Taper relief percentages: 3–4 years 20%, 4–5 years 40%, 5–6 years 60%, 6–7 years 80%; The relief reduces the tax and not the value of the transfer. Use the tax table provided in the exam.

How to solve Due Dates and Liability for Payment of IHT questions

Use the same sequence for any question on IHT due dates and liability. It stops you mixing up the lifetime and death rules.

1Identify each transfer: CLT, PET, or the death estate. State the date of transfer and the date of death if relevant.
2Decide which tax you are dealing with: lifetime tax at 20%, death tax on a failed PET or CLT at 40%, or tax on the death estate at 40%.
3Work out the due date. For a CLT, take the later of 30 April after the end of the tax year of transfer and six months after the end of the month of transfer. For a transfer from 6 April to 30 September, that is 30 April next year. For death, take the end of the month of death and add six months.
4Name the person or people primarily liable: the donor and the trustees together for lifetime tax on a CLT, the donee for a failed PET, the trustees for additional tax on a CLT, the personal representatives for the estate.
5Name the secondary liable persons: the personal representatives for failed PET tax (only to the extent the donee does not pay) and for additional CLT tax (only to the extent the trustees do not pay), and the recipients of estate property. For lifetime tax on a CLT, note that the trustees often pay by agreement.
6If the donor pays the lifetime tax, gross up the excess over the nil rate band at 20/80. If the trustees pay, do not gross up.
7Add any interest or cash flow consequence if the question asks about late payment, and link it to the facts given.
8Write your answer in short, clear points: transfer, due date, who pays, and why.

Quickest way: Date and payer check

When to use it: Use this when the question gives you a list of gifts and asks only for due dates and who pays. It is also useful when you are short of time.

Write the date of each gift or death in the margin, with the month in capitals.
For each CLT, tick April to September or October to April. Use 30 April next year for the first, and month end plus six months for the second.
For each death-related tax, take the month of death and add six months to its end.
Write the payer next to each: donor and trustees for a CLT, donee for a failed PET, personal representatives for the estate.
Add one line on secondary liability for each item.
Check any grossing up only when the donor pays the lifetime tax.

Common mistakes in Due Dates and Liability for Payment of IHT

Using six months after the date of the gift for a lifetime transfer made between April and September.
Students learn the death rule and apply it everywhere.
Fix: Remember the rule is the later of 30 April after the tax year end and six months after the end of the month of transfer. A CLT made from 6 April to 30 September is due on 30 April of the following year.
Counting six months from the date of death rather than from the end of the month of death.
Students rush and skip the month end step.
Fix: Always write the month end first. A death on 12 March is followed by month end 31 March, and the due date is 30 September.
Saying the personal representatives pay tax on a failed PET.
Students link death with the estate.
Fix: The donee is primarily liable for tax on a failed PET. The personal representatives are secondarily liable, and only to the extent the tax is unpaid because the donee has not paid.
Forgetting to gross up a CLT when the donor pays the tax.
Students focus on the due date and forget the calculation.
Fix: If the donor pays, gross up the excess of the net gift over the nil rate band at 20/80. If the trustees pay, no grossing up is needed.
Applying taper relief to the value of the gift instead of the tax.
Students misread what the relief reduces.
Fix: Taper relief reduces the tax payable on a gift made more than three years before death. It has no effect where the gift falls within the nil rate band, because no tax arises.
Treating a PET as taxable at the time it is made.
Students confuse PETs with CLTs.
Fix: A PET has no lifetime tax. Tax only arises if the donor dies within seven years.

Worked examples

Example 1

Anna makes a gift of £500,000 to a discretionary trust on 20 August 2025. This is her first transfer and she has made no earlier gifts. Assume annual exemptions are ignored. The trustees agree to pay any tax. State the due date, who is liable, and calculate the lifetime IHT.

Show the solution

The gift to a discretionary trust is a CLT.
The transfer is made on 20 August 2025, which is between 6 April and 30 September. The later of 30 April 2026 and 28 February 2026 (six months after the end of August) is 30 April 2026. The tax is due on 30 April 2026.
The trustees have agreed to pay, so the tax is not grossed up. Use the 20% lifetime rate.
Excess over the nil rate band is £500,000 less £325,000, which is £175,000.
Tax is £175,000 × 20%, which is £35,000.
Anna, the donor, and the trustees are both primarily liable. Because the trustees have agreed to pay, they pay in practice.

Answer: The tax is £35,000. It is due on 30 April 2026. Anna and the trustees are both primarily liable. The trustees pay as agreed.

Example 2

Ben gives his son shares worth £400,000 on 10 July 2022. This is a PET and Ben has made no other gifts. Ignore annual exemptions. Ben dies on 15 February 2026. State the due date, who is liable, and calculate the IHT payable. Ben's nil rate band is fully available against this gift.

Show the solution

The PET becomes chargeable because Ben died within seven years.
Death occurred on 15 February 2026. The end of that month is 28 February 2026. Six months later is 31 August 2026. The tax is due on 31 August 2026.
The gap between gift and death is from 10 July 2022 to 15 February 2026. This is more than three but less than four years, so taper relief is 20%.
The PET is set against the nil rate band first. Excess over the nil rate band is £400,000 less £325,000, which is £75,000.
Tax at the death rate is £75,000 × 40%, which is £30,000.
Taper relief reduces the tax by 20%, which is £6,000. Tax payable is £24,000.
The £400,000 PET exceeds the £325,000 nil rate band, so the whole band is used against the PET and none is left for Ben's death estate. Had the PET been smaller than the band, the unused band would be available to the estate.
The donee, Ben's son, is primarily liable. The personal representatives are secondarily liable if the son does not pay.

Answer: The tax is £24,000. It is due on 31 August 2026. Ben's son is primarily liable, and Ben's personal representatives are secondarily liable. The £400,000 PET exceeds the nil rate band, so the whole band is used and none is left for the death estate.

Exam tips

Write the due date in full as a calendar date. Examiners award a mark for the date and a mark for the reasoning.
Always state primary and secondary liability when the question says who is liable. One name alone usually loses marks.
Use the tax table in the exam for the nil rate band, the rates and the taper relief bands. Do not rely on memory for percentages.
If the scenario is about advising a client, add one cash flow point. For example, tell the client when funds are needed and who must supply them.
Show the month end step in your working. It protects marks if you slip on the final date.

Practice questions from Inheritance tax: administration and payment, including the instalment option

Due Dates and Liability for Payment of IHT in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

Due Dates and Liability for Payment of IHT: frequently asked questions

When is IHT due on a lifetime gift?

Tax on a chargeable lifetime transfer is due on the later of 30 April after the end of the tax year of transfer and six months after the end of the month of transfer. If the transfer is made from 6 April to 30 September, that is 30 April of the next tax year. If it is made from 1 October to 5 April, it is six months after the end of the month of transfer. A PET has no lifetime tax.

Who pays IHT on a failed PET?

The donee is primarily liable for the tax on a failed PET. The donor's personal representatives are only secondarily liable if the donee does not pay. The tax is due six months after the end of the month of death.

What is the difference between primary and secondary liability for IHT?

The person primarily liable is the first one HMRC looks to for payment. A person with secondary liability only has to pay if the primary person does not. Exam answers should name both where the question asks who is liable.

Who pays the IHT on the death estate?

The personal representatives are primarily liable for tax on the assets they deal with. They pay it from the estate. Recipients of property can have secondary liability, and trustees are liable for tax on trust assets.

Does the donor's death change the tax on a lifetime CLT?

It can. If the donor dies within seven years of a CLT, the transfer is taxed again at the death rate of 40%, after taper relief where it applies. Tax already paid in lifetime is deducted. The additional tax is due six months after the end of the month of death. The trustees are primarily liable for it. The personal representatives are secondarily liable, and only to the extent the trustees do not pay.