IHTM14711 - GWRs: when double charges relief arises

Relief under the Inheritance Tax (Double Charges Relief) Regulations 1987 (SI1987/1130) Reg.5 will apply in instances where a failed PET ( IHTM14511), or an immediately chargeable transfer ( IHTM04067), is also a GWR ( IHTM14301) and becomes chargeable a second time on the transferor’s death because either

• the reservation continued to the date of death so that the property concerned is treated by FA86/S102 (3) as property which the deceased was beneficially entitled

or

• the property ceased to be subject to a reservation before the death and became the subject of a PET.