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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
, see all updates

Lifetime transfers: contents

Introduction
  1. IHTM14001
    Introduction
Basis of valuation
  1. IHTM14011
    Basis of valuation: Summary
  2. IHTM14012
    Basis of valuation: Burden of tax
  3. IHTM14013
    Basis of valuation: Treatment of expenses
Specific lifetime exemptions
  1. IHTM14131
    Specific lifetime exemptions: Summary
  2. IHTM14132
    Specific lifetime exemptions: Order in which exemptions apply
Annual exemption
  1. IHTM14141
    Annual exemption: Summary
  2. IHTM14142
    Annual exemption: Relievable property
  3. IHTM14143
    Annual exemption: Multiple transfers
  4. IHTM14144
    Annual exemption: Roll over provisions
Schemes to exploit annual exemption
  1. IHTM14151
    Schemes to exploit annual exemption: Introduction
  2. IHTM14152
    Schemes to exploit annual exemption: Transfer by sale
  3. IHTM14161
    Schemes to exploit annual exemption: Transfer of part of a property
  4. IHTM14162
    Schemes to exploit annual exemption: Transfer of sum of money
  5. IHTM14163
    Schemes to exploit annual exemption: Transfer of share equal to a sum of money
  6. IHTM14164
    Schemes to exploit annual exemption: Transfer of shares quantified by loss in value
  7. IHTM14165
    Schemes to exploit annual exemption: Split proceeds from property on trust for sale
Small gifts exemption
  1. IHTM14180
    Small gifts exemption: Summary
Gifts in consideration of marriage or registration of civil partnership
  1. IHTM14191
    Gifts in consideration of marriage or registration of civil partnership: Summary
  2. IHTM14193
    Gifts in consideration of marriage or registration of civil partnership: Permissible beneficiaries for s.22 purposes
  3. IHTM14201
    Gifts in consideration of marriage or registration of civil partnership: Rennell v IRC
  4. IHTM14202
    Gifts in consideration of marriage or registration of civil partnership: Rennell v IRC - gifts by way of settlement
  5. IHTM14211
    Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - outright gifts and other dispositions
  6. IHTM14212
    Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - the eventual recipient
  7. IHTM14213
    Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - IHTA84/S22 (4)(b) provisions
  8. IHTM14214
    Gifts in consideration of marriage or registration of civil partnership: IHTA restrictions of Rennell - payments under covenant
  9. IHTM14220
    Gifts in consideration of marriage or registration of civil partnership: Relationship with spouse or civil partner exemptions
  10. IHTM14221
    Gifts in consideration of marriage or registration of civil partnership: Termination of IIP in settled property
Normal expenditure out of income
  1. IHTM14231
    Normal expenditure out of income: Introduction
  2. IHTM14235
    Normal expenditure out of income: Life policy linked with an annuity
  3. IHTM14236
    Normal expenditure out of income: Loans
Conditions for normal out of income exemption
  1. IHTM14241
    Conditions for normal out of income exemption: Normal expenditure
  2. IHTM14242
    Conditions for normal out of income exemption: Pattern of gifts
  3. IHTM14243
    Conditions for normal out of income exemption: Factors to consider
  4. IHTM14244
    Conditions for normal out of income exemption: Case Law - Bennett v IRC
  5. IHTM14250
    Conditions for normal out of income exemption: Out of income
  6. IHTM14251
    Conditions for normal out of income exemption: Case Law - McDowall
  7. IHTM14255
    Conditions for normal out of income exemption: Transferor's standard of living
Gifts with reservation (GWRs)
  1. IHTM14301
    Gifts with reservation (GWRs): Requirements for a GWR
  2. IHTM14303
    Gifts with reservation (GWRs): Devolution of GWR property
Gifts with reservation (GWRs): The gift
  1. IHTM14311
    Gifts with reservation (GWRs): The gift: Initial requirements
  2. IHTM14312
    Gifts with reservation (GWRs): The gift: The donor
  3. IHTM14313
    Gifts with reservation (GWRs): The gift: The property given
  4. IHTM14314
    Gifts with reservation (GWRs): The gift: Examples of the property given - carve-out arrangements
  5. IHTM14315
    Gifts with reservation (GWRs): The gift: Defining the gift
  6. IHTM14316
    Gifts with reservation (GWRs): The gift: Sales for less than full consideration
  7. IHTM14317
    Gifts with reservation (GWRs): The gift: Interest free loans
  8. IHTM14318
    Gifts with reservation (GWRs): The gift: Exempt transfers which cannot be GWRs
  9. IHTM14319
    Gifts with reservation (GWRs): The gift: Exempt transfers which can be GWRs
Gifts with reservation (GWRs): The reservation
  1. IHTM14331
    Gifts with reservation (GWRs): The reservation: Initial requirements
  2. IHTM14332
    Gifts with reservation (GWRs): The reservation: Possession and enjoyment by the donee
  3. IHTM14333
    Gifts with reservation (GWRs): The reservation: Exclusion of the donor
  4. IHTM14334
    Gifts with reservation (GWRs): The reservation: Examples of exclusion of the donor
  5. IHTM14335
    Gifts with reservation (GWRs): The reservation: Non-exclusion need not be continuous
  6. IHTM14336
    Gifts with reservation (GWRs): The reservation: Effect of consideration
  7. IHTM14337
    Gifts with reservation (GWRs): The reservation: Continuation of reasonable commercial arrangements
  8. IHTM14338
    Gifts with reservation (GWRs): The reservation: Benefit by associated operations
  9. IHTM14339
    Gifts with reservation (GWRs): The reservation: Benefit to donor's spouse or civil partner
  10. IHTM14340
    Gifts with reservation (GWRs): The reservation: When occupation is not a reservation
  11. IHTM14341
    Gifts with reservation (GWRs): The reservation: Full consideration in cases of land and chattels
  12. IHTM14342
    Gifts with reservation (GWRs): The reservation: Infirm relative
  13. IHTM14343
    Gifts with reservation (GWRs): The reservation: Annual exemption
  14. IHTM14360
    Gifts with reservation (GWRs): The reservation: Interests in land
Gifts with reservation (GWRs): Tracing
  1. IHTM14371
    Gifts with reservation (GWRs): Tracing: Introduction
  2. IHTM14372
    Gifts with reservation (GWRs): Tracing: Absolute gifts of cash
  3. IHTM14373
    Gifts with reservation (GWRs): Tracing: Absolute gifts of property other than cash
  4. IHTM14374
    Gifts with reservation (GWRs): Tracing: Supplementary provisions
Gifts with reservation (GWRs): Settled property
  1. IHTM14391
    Gifts with reservation (GWRs): Settled property: Introduction
  2. IHTM14392
    Gifts with reservation (GWRs): Settled property: The donee and the property given
  3. IHTM14393
    Gifts with reservation (GWRs): Settled property: Settlement on discretionary trusts
  4. IHTM14394
    Gifts with reservation (GWRs): Settled property: Donor also a trustee
  5. IHTM14395
    Gifts with reservation (GWRs): Settled property: Reasonable commercial arrangements
  6. IHTM14396
    Gifts with reservation (GWRs): Settled property: Settlement created when the settlor is domiciled outside the UK
Gifts with reservation (GWRs): Tracing settled property
  1. IHTM14401
    Gifts with reservation (GWRs): Tracing settled property: The property comprised in the gift
  2. IHTM14402
    Gifts with reservation (GWRs): Tracing settled property: If the property ceases to be settled
  3. IHTM14403
    Gifts with reservation (GWRs): Tracing settled property: Settlement by the donee
Gifts with reservation (GWRs): Insurance policies
  1. IHTM14421
    Gifts with reservation (GWRs): Insurance policies: Introduction
  2. IHTM14431
    Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: General gifts after 18 March 1986
  3. IHTM14432
    Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Normal out of income exemption on regular premiums
  4. IHTM14433
    Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Policies made before 18 March 1986
  5. IHTM14434
    Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Automatic increases in policy value
  6. IHTM14435
    Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: Change in life assured
  7. IHTM14440
    Gifts with reservation (GWRs): Insurance policies - gifts to which the GWR rules can apply: The property given
Gifts with reservation (GWRs): The reservation on insurance policies
  1. IHTM14451
    Gifts with reservation (GWRs): The reservation on insurance policies: Introduction
  2. IHTM14452
    Gifts with reservation (GWRs): The reservation on insurance policies: Special rule for policies with linked benefits
  3. IHTM14453
    Gifts with reservation (GWRs): The reservation on insurance policies: Reservation examples
The charge to tax
  1. IHTM14502
    The charge to tax: Cumulation
  2. IHTM14503
    The charge to tax: Cumulation with the death estate
The charge to tax: Potentially exempt transfers (PETs)
  1. IHTM14511
    The charge to tax: Potentially exempt transfers (PETs): Tax treatment of a PET
  2. IHTM14512
    The charge to tax: Potentially exempt transfers (PETs): Tax treatment of a PET followed by death
  3. IHTM14513
    The charge to tax: Potentially exempt transfers (PETs): Cumulation
  4. IHTM14514
    The charge to tax: Potentially exempt transfers (PETs): Cumulating transfers more than seven years before death
  5. IHTM14515
    The charge to tax: Potentially exempt transfers (PETs): IHT nil rate band
  6. IHTM14516
    The charge to tax: Potentially exempt transfers (PETs): Rate of tax
  7. IHTM14517
    The charge to tax: Potentially exempt transfers (PETs): Taper relief
  8. IHTM14518
    The charge to tax: Potentially exempt transfers (PETs): Fall in value relief
  9. IHTM14519
    The charge to tax: Potentially exempt transfers (PETs): Special rate
The charge to tax: Immediately chargeable transfers
  1. IHTM14531
    The charge to tax: Immediately chargeable transfers: Introduction
  2. IHTM14532
    The charge to tax: Immediately chargeable transfers: Value for tax
  3. IHTM14533
    The charge to tax: Immediately chargeable transfers: Cumulation
  4. IHTM14534
    The charge to tax: Immediately chargeable transfers: Rate of tax
The charge to tax: Grossing
  1. IHTM14541
    The charge to tax: Grossing: When to gross-up
  2. IHTM14542
    The charge to tax: Grossing: When not to gross-up
  3. IHTM14543
    The charge to tax: Grossing: Partial grossing
  4. IHTM14544
    The charge to tax: Grossing: The grossing calculation
  5. IHTM14545
    The charge to tax: Grossing: Tax paid after death of the transferor
  6. IHTM14546
    The charge to tax: Grossing: Settled property
  7. IHTM14547
    The charge to tax: Grossing: Authority for grossing
The charge to tax: Other charges
  1. IHTM14550
    The charge to tax: Other charges: Late reported transfers
  2. IHTM14551
    The charge to tax: Other charges: Death subsequent to the transfer
The charge to tax: Additional charges
  1. IHTM14571
    The charge to tax: Additional charges: Introduction
  2. IHTM14572
    The charge to tax: Additional charges: Value for tax
  3. IHTM14573
    The charge to tax: Additional charges: Cumulation
  4. IHTM14574
    The charge to tax: Additional charges: Rate of tax
  5. IHTM14575
    The charge to tax: Additional charges: Taper relief
  6. IHTM14576
    The charge to tax: Additional charges: The additional tax payable
  7. IHTM14577
    The charge to tax: Additional charges: The additional tax payable (example 1)
  8. IHTM14578
    The charge to tax: Additional charges: The additional tax payable (example 2)
The charge to tax: Reliefs
  1. IHTM14579
    The charge to tax: Reliefs: Business relief and agricultural relief
  2. IHTM14580
    The charge to tax: Reliefs: Fall in value relief
The charge to tax: The charge on lifetime transfers
  1. IHTM14590
    The charge to tax: The charge on lifetime transfers: Gifts with reservation (GWRs)
  2. IHTM14591
    The charge to tax: The charge on lifetime transfers: Simultaneous and same day transfers
  3. IHTM14592
    The charge to tax: The charge on lifetime transfers: Liability for payment of tax
  4. IHTM14593
    The charge to tax: The charge on lifetime transfers: Grossing-up the values
  5. IHTM14595
    The charge to tax: The charge on lifetime transfers: Late reported transfers
Specific lifetime reliefs: Taper relief
  1. IHTM14611
    Specific lifetime reliefs: Taper relief: When the relief applies
  2. IHTM14612
    Specific lifetime reliefs: Taper relief: Quantifying the relief
  3. IHTM14613
    Specific lifetime reliefs: Taper relief: Period of survival
Specific lifetime reliefs: Fall in value relief
  1. IHTM14621
    Specific lifetime reliefs: Fall in value relief: Introduction
  2. IHTM14622
    Specific lifetime reliefs: Fall in value relief: Form of the relief
  3. IHTM14624
    Specific lifetime reliefs: Fall in value relief: Conditions for relief
  4. IHTM14625
    Specific lifetime reliefs: Fall in value relief: What is a qualifying sale?
  5. IHTM14626
    Specific lifetime reliefs: Fall in value relief: What is market value?
  6. IHTM14627
    Specific lifetime reliefs: Fall in value relief: The claim
  7. IHTM14628
    Specific lifetime reliefs: Fall in value relief: Wasting assets
  8. IHTM14629
    Specific lifetime reliefs: Fall in value relief: Portfolio of assets
  9. IHTM14630
    Specific lifetime reliefs: Fall in value relief: More than one sale
  10. IHTM14631
    Specific lifetime reliefs: Fall in value relief: Not all of the transferred assets are sold
Specific lifetime reliefs: Shares and securities
  1. IHTM14641
    Specific lifetime reliefs: Shares and securities: Adjustments
  2. IHTM14642
    Specific lifetime reliefs: Shares and securities: Capital receipts
  3. IHTM14643
    Specific lifetime reliefs: Shares and securities: Payment of calls
  4. IHTM14644
    Specific lifetime reliefs: Shares and securities: Changes in shareholdings
  5. IHTM14645
    Specific lifetime reliefs: Shares and securities: Transactions of close companies
Specific lifetime reliefs: Interests in land
  1. IHTM14661
    Specific lifetime reliefs: Interests in land: Changes between transfer and death
  2. IHTM14662
    Specific lifetime reliefs: Interests in land: Changes that have reduced the value
  3. IHTM14663
    Specific lifetime reliefs: Interests in land: Changes that have increased the value
  4. IHTM14664
    Specific lifetime reliefs: Interests in land: Compensation
  5. IHTM14670
    Specific lifetime reliefs: Interests in land: Leases
  6. IHTM14671
    Specific lifetime reliefs: Interests in land: Other property
Double charges relief
  1. IHTM14691
    Double charges relief: When double charges arise
  2. IHTM14692
    Double charges relief: Applying the relief
  3. IHTM14693
    Double charges relief: Authority for the relief
Double charges relief: Potentially exempt transfers (PETs)
  1. IHTM14701
    Double charges relief: Potentially exempt transfers (PETs): When double charges relief arises
  2. IHTM14702
    Double charges relief: Potentially exempt transfers (PETs): Partial consideration
  3. IHTM14703
    Double charges relief: Potentially exempt transfers (PETs): Property representing the property transferred
  4. IHTM14704
    Double charges relief: Potentially exempt transfers (PETs): Calculations
  5. IHTM14705
    Double charges relief: Potentially exempt transfers (PETs): Quick succession relief (QSR)
Double charges relief: Gifts with reservation (GWRs)
  1. IHTM14711
    Double charges relief: Gifts with reservation (GWRs): When double charges relief arises
  2. IHTM14712
    Double charges relief: Gifts with reservation (GWRs): Calculations
  3. IHTM14713
    Double charges relief: Gifts with reservation (GWRs): Example of calculations 1
  4. IHTM14714
    Double charges relief: Gifts with reservation (GWRs): Example of calculations 2
Double charges relief: Disallowed debts
  1. IHTM14721
    Double charges relief: Disallowed debts: When double charges relief arises
  2. IHTM14722
    Double charges relief: Disallowed debts: Calculations
  3. IHTM14730
    Double charges relief: Disallowed debts: Transfers chargeable when made
  4. IHTM14731
    Double charges relief: Disallowed debts: Calculations producing the same amount
  5. IHTM14732
    Double charges relief: Disallowed debts: Discretionary trusts
Omissions
  1. IHTM14802
    Omissions: Possible omissions of lifetime transfers
  2. IHTM14810
    Omissions: Omission to exercise a right
Associated operations
  1. IHTM14821
    Associated operations: Why are the provisions necessary?
  2. IHTM14822
    Associated operations: Definition
  3. IHTM14823
    Associated operations: The objective test
  4. IHTM14824
    Associated operations: The subjective test
  5. IHTM14825
    Associated operations: Additional provisions
  6. IHTM14826
    Associated operations: Definition of terms
  7. IHTM14827
    Associated operations: Transfer of value made by associated operations
  8. IHTM14828
    Associated operations: Restrictions on association
  9. IHTM14829
    Associated operations: Re Macpherson
  10. IHTM14830
    Associated operations: Insurance policies
  11. IHTM14831
    Associated operations: Gifts With Reservation
  12. IHTM14832
    Associated operations: Transfers involving relievable property
  13. IHTM14833
    Associated operations: Gifts between spouses or civil partners
  14. IHTM14834
    Associated operations: Sale without immediate payment of the purchase price
  15. IHTM14835
    Associated operations: Transfer in stages
  16. IHTM14836
    Associated operations: Successive settlements
Transfers by close companies
  1. IHTM14851
    Transfers by close companies: Introduction
  2. IHTM14852
    Transfers by close companies: Transfers of value
  3. IHTM14853
    Transfers by close companies: Exemptions
  4. IHTM14854
    Transfers by close companies: Foreign aspects
  5. IHTM14855
    Transfers by close companies: Alterations in share capital, loan capital or rights
  6. IHTM14856
    Transfers by close companies: Liability to tax
Future payments
  1. IHTM14871
    Future payments: Introduction
  2. IHTM14872
    Future payments: Calculating the chargeable portion
  3. IHTM14873
    Future payments: Exemptions
  4. IHTM14874
    Future payments: Payments outstanding at death
Dating of dispositions
  1. IHTM14881
    Dating of dispositions: Introduction
  2. IHTM14882
    Dating of dispositions: Gifts by cheque
  3. IHTM14883
    Dating of dispositions: Dispositions affecting land
  4. IHTM14884
    Dating of dispositions: Chattels and corporeal moveables
  5. IHTM14885
    Dating of dispositions: Choses in action and incorporeal moveables
Investigation issues
  1. IHTM14890
    Investigation issues: Voidable transfers
  2. IHTM14900
    Investigation issues: Donatio Mortis Causa (DMC)