It has been suggested that IHT paid by instalments on assets qualifying for APR/BPR will be interest free. Has anyone dealt with this in practice?
My reason for asking - if you have a mix of relievable and non-relievable assets subject to the instalment option, can the IHT payment be allocated to clear down the whole of IHT on the non-relievable assets and the 1st instalment of the relievable assets, leaving the outstanding liability payable by instalments on the relievable assets (so interest free)?
Or does the payment of IHT need to be apportioned between the liabilities due on relievable and non-relievable assets based on their IHT liabilities, resulting in outstanding liabilities remaining on the relievable assets which will be subject to interest charges.
SS.227-9 set out the types of property qualifying for instalments and s.234(1) limits interest to unpaid instalments only for certain specified qualifying property among those types:
1 the value of property eligible for APR or BPR;
2 the value of shares, securities, a business or an interest in a business not so eligible but falling within s.228;
3 a chargeable transfer of woodlands within s.129
An apportionment of the tax is implicitly required by the connection with “the value” in 1 and 2 and “the transfer” in 3 which is related to “the value” of land within s.125. It necessitates an attribution of the tax charge to each item of qualifying property where it does not comprise the entirety of a chargeable transfer.