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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: gifts with reservation (GWRs): the reservation: initial requirements

In considering the reservation you are concerned with establishing whether:

  • the donee assumed bona fide possession and enjoyment (IHTM14332),
  • the donor was entirely excluded (IHTM14333)..

If either requirement is not satisfied, the gift is one with reservation.

You will also have to consider the impact of any changes in the property given (IHTM14313).

There are separate instructions relating to insurance policies (IHTM14451).