Chapter IHTM30033

CourtHM Revenue & Customs
Record NumberIHTM30033
Published date20 March 2016

The liability of a personal representative (IHTM05012) is a personal one. Its character as a personal liability is not affected by the limitation on the amount of the liability by virtue of IHTA84/S204 (1).

See IRC v Stannard [1984] STC 245, CTT Cases No. 22.

Although limitations (IHTM30032) may apply, the liability of a personal representative for IHT is not affected by the fact that for example the deceased may

  • leave two Wills as in Ld. Advocate v Douglas’s Exors [1911] 55 Rep. CIR, one appointing British executors for his British property, and one appointing foreign executors for his foreign property
  • leave one Will as in Re Manchester (Dowager Duchess), Duncannon (Viscount) v Manchester...

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