Gifts with reservation ― further provisions

By Tolley
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The following Trusts and Inheritance Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Gifts with reservation ― further provisions
  • Introduction
  • Agricultural property relief (APR) and business property relief (BPR)
  • Substitutions of and accretions to property subject to a reservation
  • Variations in distribution of deceased estate

Introduction

This guidance note looks at the specific gifts with reservation rules regarding:

  • agricultural and business property
  • substitutions and accretions

These additional rules are to be found in FA 1986, Sch 20.

It also considers the gift with reservation (GWR) consequences when a person redirects property he has inherited under an instrument of variation.

Agricultural property relief (APR) and business property relief (BPR)

Special rules apply where a donor reserves a benefit in a gift which qualifies for BPR or APR. The availability of those reliefs depends on:

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