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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: gifts with reservation (GWRs): the gift: exempt transfers which can be GWRs

The main exemptions which do not prevent application of the gift with reservation (GWR) rules are

  • IHTA84/S3A (4) - PET made seven years or more before the death of the transferor (IHTM14511)
  • IHTA84/S19 - Annual exemption (IHTM14141)
  • IHTA84/S21 - Normal out-of-income exemption (IHTM14231)

A gift which is an exempt transfer under the above exemptions may be chargeable under the GWR rules, as may a gift which is an exempt transfer under any other section not listed at IHTM14318.

Small gifts exemption (IHTM14180)

Strictly speaking the small gifts exemption is only available in respect of outright gifts.