IHTM30071 - Definition and extent of liability (lifetime transfers chargeable when made): transferor
Under IHTA84/S3 (1) the main meaning of transferor is a person who makes a disposition (IHTM04023) which reduces the value of their estate. For deemed transfers of value, see IHTA84/S3 (4).
The transferor is primarily liable for the tax payable. IHTA84/S204, limitation of liability section, contains no provisions limiting the liability of the transferor under IHTA84/S199 (1)(a).