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HMRC internal manual

Inheritance Tax Manual

Gifts for National Purposes: qualifications specific to the exemption

The exemption is subject to the same exclusions (IHTM11171) that apply to charity exemption (IHTM11101), but with certain qualifications under IHTA84/S25 (2) which allow exemption that would otherwise be excluded. The situations where IHTA84/S25 (2) applies to allow the exemption are:

  • the IHTA84/S23 (3) exclusion of gifts of less than the donor’s whole interest or for a limited period (IHTM11176) does not prevent the IHTA84/S25 (1) exemption from applying to property consisting of the benefit of an agreement restricting the use of land
  • gifts of land to the National Trust may be accompanied by a memorandum of wishes under which the donor or other person is permitted to reside in the house and receive the rent during their lifetime. The memorandum has no legal force and the reservation, no matter for whose benefit, does not prevent exemption under IHTA84/S25 from applying.