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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: gifts with reservation (GWRs): tracing settled property: settlement by the donee

Where property is not settled by the gift but is subsequently settled by the done:

  • For the period between the gift and the settlement by the donee, the normal tracing rules apply (IHTM14371).
  • But, from the date of the settlement by the donee, the settled property tracing rules apply (IHTM14401). For this purpose, treat property which is settled by the donee’s will or intestacy as settled by the donee.