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HMRC internal manual

Inheritance Tax Manual

Liability on gifts with reservation (GWRs): definition and extent of liability

Persons liable under IHTA84/S200 (1)(c)

These are the same as for other transfers on death (IHTM30035).

Personal representatives of the deceased

The instructions relating to the secondary liability of the personal representatives (IHTM05012) of the transferor for tax on a potentially exempt transfer (IHTM30043) apply. The limitation (IHTM30032) in IHTA84/S204 (1) applies.


Trustees will normally be liable as persons in whom property is vested under IHTA84/S200 (1)(c). There are limitations (IHTM30101) on their liability.

Recipients of benefit from settled property (IHTA84/S200 (1)(d))

The limitation (IHTM30037) in IHTA84/S204 (5) applies.