Druces LLP

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Matthew Duncan
Partner
Druces LLP
Zoe Elizabeth Norton
Solicitor
Druces LLP
Contributions by Druces LLP Experts

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IHT—gifts with reservation of benefit
IHT—gifts with reservation of benefit
Practice Notes

This Practice Note, maintained in partnership with Matthew Duncan and Zoe Norton of Druces LLP, provides a summary of the gift with reservation of benefit (GWR or GROB) regime under section 102 of the Finance Act 1986. If a GWR has occurred and there is a reserved benefit such that the donee did not take possession or did not enjoy the gifted property to the entire exclusion or virtually to the entire exclusion of the donor, the value of that gift will form part of the donor’s estate for inheritance tax (IHT) purposes on death. This Practice Note considers when a disposal may be subject to a reservation of benefit, exceptions from the regime, its interaction with the pre-owned assets charge (POA charge or POAT) and how the GWR regime applies in practice.

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