1063. Relief from double charge to tax.

Relief from a double charge to tax is provided for in respect of transfers of value and other events occurring on or after 18 March 1986, where:

  1.  

    (1)     property given by a potentially exempt transfer1 is subsequently returned (otherwise than for full consideration) by the donee to the transferor, and as a result of the transferor's death both that property and the potentially exempt transfer become chargeable to tax2;

  2.  

    (2)     there is a transfer of value by way of gift of property which is or subsequently becomes a chargeable transfer3, and the property is (by virtue of the provisions