Readers’ forum: Order of reliefs after donor’s unexpected death

I am dealing with an estate where the deceased made a chargeable lifetime transfer and potentially exempt transfer on the same day.

The potentially exempt transfer subsequently failed because of the earlier than expected death of the donor. I am trying to work out the liability and in particular how to use the nil rate band. Should it be apportioned between the two transfers or given to one of the transfers in preference to the other?

This got me thinking about how to advise clients in future. If they are intending to make transfers one of which is a potentially exempt transfer and one a chargeable lifetime transfer. Is there any advantage from an inheritance tax perspective to having the two transfers occur on the same day or is it better than they should happen on different days. Readers’ thoughts would be gratefully received.

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