IHTM14212 - IHTA restriction of Rennell: the eventual recipient

A further restriction by IHTA84/S22 (3) and (4) means you must be careful to also identify the true donees of gifted property. If the donee takes the property under a legal obligation to transfer it to other persons who do not satisfy these subsections, the exemption is lost.

However, if the donee is not under a legal obligation but subsequently transfers it voluntarily, you can disregard that transfer, even though the gift was made in the hope that they would act in the way they have. The subsequent voluntary transfer may of course need investigation for IHT purposes as a separate disposition.