Commentary

I3.735 General scheme of exemptions

IHT, trusts and estates

I3.735 General scheme of exemptions

Pre-owned assets: exemptions

I3.735 General scheme of exemptions

There are a number of exemptions from the pre-owned assets charge otherwise arising on land, chattels or intangible property, and these fall broadly into five categories, namely exemptions for:

  1.  

    •     property that is in the taxpayer's estate for inheritance tax (see I3.736)

  2.  

    •     property that is deemed to be in the taxpayer's estate under the gifts with reservation of benefit ('GWR') provisions (see I3.737)

  3.  

    •     property that escapes from the GWR provisions by virtue of certain specified inheritance tax exemptions or reliefs (see I3.738)1

  4.  

    •     property covered by certain equity release

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