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HMRC internal manual

Inheritance Tax Manual

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 gift with reservation (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.