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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: gifts with reservation (GWRs): the reservation: infirm relative

You should disregard the donor’s occupation of gifted land, or any part of it, where the occupation

  • results from an unforeseen change in the donor’s circumstances,
  • the donor is unable to maintain themself through old age or infirmity, and
  • the occupation represents reasonable provision by the donee for their care and maintenance.

This only applies if the donee is a relative of the donor or of the donor’s spouse or civil partner.

The authority for this concession is at FA86/Sch20/para 6(1)(b).


A perfectly healthy donor, Stephen, gives his house to his son, Peter, but five years later becomes ill with motor neurone disease. As a result of this he has to move back to his former house to be cared for by Peter. Stephen’s occupation has resulted from an unforeseen change in his circumstances, and that occupation represents reasonable provision for his care and maintenance.