Inheritance Tax Act 1984 section 205

More than one person liable

Section 205 deals with the position where more than one person is liable for the same inheritance tax charge, establishing that each person is jointly and severally liable for the full amount.

• Where two or more persons are liable for the same inheritance tax, each person is liable for the whole amount, not just a proportionate share.
• HMRC can pursue any one of the liable persons for the full tax due, rather than having to apportion it between them.
• This joint and several liability applies unless another provision of the Act specifically provides otherwise.
• A person who pays more than their fair share may have a right to recover contributions from the other liable persons, but HMRC is not concerned with how the burden is split between them.