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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: gifts with reservation (GWRs): the reservation: when occupation is not a reservation

There are two circumstances in which the donor’s occupation of gifted land is not treated as a reservation. They are, very broadly

  • where the occupation was for full consideration (IHTM14341) (this also applies to chattels), or
  • where it represents reasonable provision for an infirm relative (IHTM14342).