IHTM30084 - Liability on gifts with reservation (GWRs): definition and extent of liability

Persons liable under IHTA84/S200 (1)(c)

These are the same as for other transfers on death ( IHTM30035).

Personal representatives of the deceased

The instructions relating to the secondary liability of the personal representatives ( IHTM05012) of the transferor for tax on a PET ( IHTM30043) apply. The limitation ( IHTM30032) in IHTA84/S204 (1) applies.

Trustees

Trustees will normally be liable as vestees under IHTA84/S200 (1)(c). There are limitations ( IHTM30101) on their liability.

Recipients of benefit from settled property (IHTA84/S200 (1)(d))

The limitation ( IHTM30037) in IHTA84/S204 (5) applies.