Liabilty for tax on GROB

I have a post 2006 IIP trust whereby the settlor transferred her property and retained a right to reside during her lifetime (classic trust sold for care home fees purpose).

She has virtually no other monies in bank accounts. Primary liability for the GROB is on the estate but if there is no money to pay the tax will HMRC go after the Trustees for the tax? Could anyone point me in the right direction in relation to the correct legislation?

Michelle Collins
Cozens Hardy LLP

Primary liability is on the trustees not the estate

Simon Northcott