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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: specific lifetime reliefs: gifts with reservation (GWRs): when double charges relief arises

Relief under the Inheritance Tax (Double Charges Relief) Regulations 1987 (SI1987/1130) Reg.5 will apply in instances where a failed potentially exempt transfer (PET) (IHTM14511), or an immediately chargeable transfer (IHTM04067), is also a GWR (IHTM14301) and the asset transferred becomes chargeable a second time on the transferor’s death because either

  • the reservation continued to the date of death so that the asset concerned is treated by FA86/S102(3) as property which the deceased was beneficially entitled to, or
  • the asset ceased to be subject to a reservation before the death and became a deemed PET (IHTM04064) on that date.