Inheritance Tax Act 1984 section 231

Powers to transfer property in satisfaction of tax

Section 231 deals with the power to transfer property directly to HMRC in satisfaction of an inheritance tax liability, instead of selling the property and paying the tax in cash.

• Where a person has the power to sell property to raise funds to pay inheritance tax, they may instead agree with HMRC to transfer the property itself in satisfaction of the tax due.
• Such an agreement is treated for all purposes as if it were a sale carried out under the original power of sale, except that the consideration is the acceptance of property rather than cash.
• The tax that can be satisfied in this way includes not only the inheritance tax itself but also any interest that has accrued on unpaid tax.
• This provision does not override the specific rules relating to conditional exemption for deaths occurring before 7 April 1976.