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HMRC internal manual

Inheritance Tax Manual

Gifts with reservation: Introduction

Assets charged under the gift with reservation (GWR) rules have to satisfy two conditions to qualify for business relief

  • at the time of the gift the asset given has to be relevant business property (IHTM25141), and
  • at the time of the GWR charge (on the death of the donor or earlier release of the reservation) the asset would qualify for business relief if the donee then made a notional transfer of value (IHTM25382) of it.