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.
