Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
, see all updates

Lifetime transfers: specific lifetime reliefs: double charges relief: when double charges arise

You will need to consider the relief when there is more than one claim to Inheritance Tax on the same property.

In particular, for transfers on or after 18 March 1986, when the following circumstances occur

Potentially Exempt Transfers (PETs) (IHTM14701)

A PET becomes a chargeable transfer and the asset transferred by the PET has returned to the transferor and is included in their death estate e.

Gifts With Reservation (GWRs) (IHTM14711)

There is a lifetime claim on the gift of an asset which is also a GWR and the asset is therefore also treated as forming part of the death estate.

Disallowed debts (IHTM14721)

There is a lifetime charge on a transfer and the transferee has made a loan to the transferor which is a liability of the transferor’s estate at their death but which is not deductible for IHT because of FA86/S103

Immediately chargeable transfers (IHTM14730)

There is an immediately chargeable lifetime transfer and the asset transferred has returned to the transferor and is included in their death estate.