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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
, see all updates

Lifetime transfers: gifts with reservation (GWRs): tracing settled property: if the property ceases to be settled

If all or part of the settled property ceases to be settled while the reservation still exists:

  • treat the property which leaves the settlement as property comprised in the gift unless the donor then becomes absolutely and beneficially entitled to it.
  • also treat any consideration (not consisting of rights under the settlement) the donor gives for any of the settled property acquired as property comprised in the gift.

If only part of the property settled by the donor ceases to be settled, the property remaining in the settlement and subject to the reservation is also property comprised in the gift.