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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Transfers on death: introduction

Instalments are available for chargeable transfers made on death for the tax attributable to the value, including any addition for grossing up (IHTM26121), of six categories of qualifying property (IHTM30212).

By reason of FA86/S102 (3), the transfer on death includes property taxable as a GWR (IHTM04071) because it was subject to a reservation at the death of the donor. However, because GWRs involve a lifetime gift, the application of the instalment provisions to them (IHTM30271) needs separate consideration.