IHT Accountability: time limits and forms

The following questions relate to a settlor who has recently set up four discretionary Discounted Gift Trusts on consecutive dates. The combined discounted value of the transfers is more than her nil rate band so she has a lifetime IHT liability to report.

  1. How long does she have to submit forms IHT 100 and 100A?
  2. Does she need to submit four 100A forms (one for each trust)?
  3. Prudential’s discount calculator result is 48.53% and Transact’s is 44.37%. Which one will HMRC accept?

1.The time limit for submission of forms IHT100 & supplementary forms etc.is 6 months from the end of the month in which the transfer(s) occurred. This is also the due date for any payment of tax which may be due.
2.Yes a separate set of forms will be required for each trust
3. I have no idea, are the discounted gift trusts being administered by Prudential, Transact or A N Other? If the product is one of these I would use their discount calculator, if it is not I would use an average and supply copies the 2 results as supporting evidence, or at least provide an explanatory note. Perhaps others may have a different approach?

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  1. IHT 100 needs to be filed within 12 months of the end of the month in which the chargeable event arises.

  2. The Notes to IHT 100 provide “A separate form should be used to tell us about each individual chargeable event”.

  3. Presumably, adopt the calculator of the provider.

Malcolm Finney

Since 2014 the submission deadline for IHT100 is 6 months. Prior to that there were 2 separate filing deadlines depending on when the chargeable event occurred.
12 months is the submission deadline for IHT400

My understanding is that under s216 IHTA 1984 chargeable lifetime transfers require an account to be submitted within 12 months of the end of the month in which the transfer occurs; this also applies to charges arising under the relevant property regime re events occurring before 6 April 2014.

For relevant property events only, on or after 6 April 2014 the deadline is 6 months [IHTA. 1984 s(6)(ad)].

I should, have made my response a little clearer.

Malcolm Finney