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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Gifts with reservation of benefit: Introduction

A gift with reservation of benefit (GWR) (IHTM04071) charge arises on either

  • the death of the donor (the person who made the GWR), or
  • the release of the reservation by the donor.

The conditions for agricultural relief on property charged as a GWR depends on whether the property is

  • land or buildings to which IHTA84/S116 applies (IHTM24201), or
  • shares or securities in a company to whichIHTA84/S122 (1) applies (IHTM24203).

If the property charged is shares or securities in a company with agricultural assets to which IHTA84/S122 (1) does not apply, then agricultural relief will not be due but business relief may be relevant (IHTM24204).