The instructions in this section assume that the tax on the gift
is chargeable under the GWR (
IHTM04071) provisions in IHTA84/S102 FA
1986. You need to remember, however, that a gift taxable as a GWR
may also be taxable as a chargeable transfer either when made or,
in the case of a PET (
IHTM04057), as a result of the
donor’s death. Where this is the position, the relief for
double charges (
IHTM14711) needs to be considered.
The liability depends on whether the gift is treated as a PET
(
IHTM30082) or as part of the death
estate (
IHTM30083).
