§ Lord James Douglas-Hamiltonasked the Chancellor of the Exchequer whether, when heritage passes first to a legatee with a liferent interest and subsequently to the specific legatee, capital transfer tax is levied in Scotland separately on the liferent and on the specific legatee, or solely on the specific legatee.
§ Mr. Denzil Davies,pursuant to his reply [Official Report, 6th March 1978], gave the following information:
Where heritage is bequeathed first to one person in liferent and then to a second in fee, capital transfer tax will be chargeable, subject to the exemption normally available for transfers between spouses, on both occasions. If the deaths giving rise to these two charges are within four years of each other, quick succession relief may be due.
This corresponds with the general position for estate duty.