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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: gifts with reservation (GWRs): insurance policies: introduction

In general the gift with reservation (GWR) rules given above also apply to gifts in relation to policies. However, policies present special problems, because, for example

  • the donor will normally pay premiums, and so make gifts, over a period of years
  • they are used for tax planning.

FA86 contains special provisions directed at both these problems. The following instructions deal with these provisions and also illustrate the application of the normal GWR rules to policies. You will need to consider

  • gifts on or after 18 March 1986 (IHTM14431) to which the GWR rules can apply
  • identification of the property given (IHTM14440)
  • the reservation (IHTM14451)