IHTM22053 - Calculating QSR: value of, and tax on, earlier transfer

The value you need for part ‘B’ of the quick succession relief (QSR) formula (IHTM22051) is the amount of tax charged on the whole of the earlier chargeable transfer (IHTM04027). In a straightforward case when the tax on the earlier transfer has been finally determined or paid, you may use the total tax chargeable shown on the final calculation of tax. But in the following situations you must act as indicated.

• Tax on earlier transfer reduced by an allowance, e.g. QSR

Calculate the QSR as if the full tax (before the relief) had been paid on the earlier transfer.

• Tax on earlier transfer being paid by instalments

Calculate the QSR as if the tax had been paid in one sum unless no instalments have in fact been paid, or we are having difficulty collecting the instalments, for example where the instalments are in arrears.

• Tax on earlier transfer not yet final

Allow provisional QSR against any additional tax chargeable on your deceased’s estate. Follow the instructions for provisional repayments (IHTM31720) if this is requested by the taxpayer.

• Earlier transfer a potentially exempt transfer (PET) and death of transferor after death of your deceased

See IHTM22081.

• Tax on earlier transfer allowed on lifetime termination of part of deceased’s interest in possession in settled property

See IHTM22092.

Part ‘D’ of the QSR formula (IHTM22051) requires the value of the earlier transfer. This is the value on which the amount of tax was charged and is, in effect, the aggregate chargeable transfer less any chargeable lifetime transfers.