IHTM25381 - Gifts with reservation: Introduction

Property charged under the GWR rules has to satisfy two conditions to qualify for business relief:

• at the time of the gift the property given has to be relevant business property ( IHTM25141), and
• at the time of the GWR charge (on the death of the donor or earlier release of the reservation) the property would qualify for business relief if the donee then made a notional transfer of value ( IHTM25382) of it.