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HMRC internal manual

Inheritance Tax Manual

Gifts with reservation of benefit: Qualifying conditions (excluding shares and securities)

For land and buildings to qualify for agricultural relief where a GWR charge (IHTM24200) arises then

  • at the time the gift was made, the property given had to qualify for agricultural relief and you should consider the conditions for relief by reference to the donor’s history of ownership and occupation, at that time.
  • at the time of the GWR charge

    • the property must have been agricultural property (IHTM24030), and
    • the property would qualify for agricultural relief if it had been the subject of a notional transfer by the donee. (IHTM24205)