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Contents

Official guidance
Inheritance Tax Manual

IHTM14000 · Lifetime transfers

  • IHTM14001 · Introduction to lifetime transfers
  • IHTM14011 · Basis of valuation: summary
  • IHTM14012 · Basis of valuation: burden of tax
  • IHTM14013 · Basis of valuation: treatment of expenses
  • IHTM14131 · Specific lifetime exemptions: summary
  • IHTM14132 · Specific lifetime exemptions: order in which exemptions apply
  • IHTM14141 · Annual exemption: summary
  • IHTM14142 · Annual exemption: relievable property
  • IHTM14143 · Annual exemption: multiple transfers
  • IHTM14144 · Annual exemption: roll over provisions
  • IHTM14151 · Schemes to exploit annual exemption: introduction
  • IHTM14152 · Schemes to exploit annual exemption: transfer by sale
  • IHTM14161 · Schemes to exploit annual exemption: transfer of part of a property
  • IHTM14162 · Schemes to exploit annual exemption: transfer of a sum of money
  • IHTM14163 · Schemes to exploit annual exemption: transfer of share equal to a sum of money
  • IHTM14164 · Schemes to exploit annual exemption: transfer of share quantified by loss in value
  • IHTM14165 · Schemes to exploit annual exemption: split proceeds from property on trust for sale
  • IHTM14180 · Small gifts exemption: summary
  • IHTM14191 · Gifts in consideration of marriage or registration of civil partnership: summary
  • IHTM14193 · Gifts made in consideration of marriage or registration of civil partnership: permissible beneficiaries for s.22 purposes
  • IHTM14201 · Gifts in consideration of marriage or registration of civil partnership: Rennell v IRC:
  • IHTM14202 · Gifts in consideration of marriage or registration of civil partnership: Rennell v IRC - gifts by way of settlement
  • IHTM14211 · Gifts in consideration of marriage or registration of civil partnership: IHTA restriction of Rennell - outright gifts and other dispositions
  • IHTM14212 · Gifts in consideration of marriage or registration of civil partnership: IHTA restriction of Rennell - the eventual recipient
  • IHTM14213 · Gifts in consideration of marriage or registration of civil partnership: IHTA restriction of Rennell - S22(4)(b) provisions
  • IHTM14214 · Gifts in consideration of marriage or registration of civil partnership: IHTA restriction of Rennell - payments under covenant
  • IHTM14220 · Gifts in consideration of marriage or civil partnership: relationship with spouse or civil partner exemption
  • IHTM14221 · Gifts in consideration of marriage or civil partnership: termination of IIP in settled property
  • IHTM14231 · Normal expenditure out of income: introduction
  • IHTM14235 · Normal expenditure out of income: life policy linked with an annuity
  • IHTM14236 · Normal expenditure out of income: loans
  • IHTM14241 · Conditions for normal out of income exemption: normal expenditure
  • IHTM14242 · Conditions for normal out of income exemption: pattern of gifts
  • IHTM14243 · Conditions for normal out of income exemption: factors to consider
  • IHTM14244 · Conditions for normal out of income exemption: Case Law - Bennett v IRC
  • IHTM14250 · Conditions for normal out of income exemption: out of income
  • IHTM14251 · Conditions for normal out of income exemption: Case Law - MacDowell
  • IHTM14255 · Conditions for normal out of income exemption: transferor's standard of living
  • IHTM14301 · Gifts with reservation (GWRs): requirements for a GWR
  • IHTM14303 · Gifts with reservation (GWRs): devolution of GWR property
  • IHTM14311 · Gifts with reservation (GWRs): the gift: initial requirements
  • IHTM14312 · Gifts with reservation (GWRs): the gift: the donor
  • IHTM14313 · Gifts with reservation (GWRs): the gift: the property given
  • IHTM14314 · Gifts with reservation (GWRs): the gift: examples of the property given - carve-out arrangements
  • IHTM14315 · Gifts with reservation (GWRs): the gift: defining the gift
  • IHTM14316 · Gifts with reservation (GWRs): the gift: sales for less than full consideration
  • IHTM14317 · Gifts with reservation (GWRs): the gift: interest free loans
  • IHTM14318 · Gifts with reservation (GWRs): the gift: exempt transfers which cannot be GWRs
  • IHTM14319 · Gifts with reservation (GWRs): the gift: exempt transfers which can be GWRs
  • IHTM14331 · Gifts with reservation (GWRs): the reservation: initial requirements
  • IHTM14332 · Gifts with reservation (GWRs): the reservation: possession and enjoyment by the donee
  • IHTM14333 · Gifts with reservation (GWRs): the reservation: exclusion of the donor
  • IHTM14334 · Gifts with reservation (GWRs): the reservation: examples of exclusion of the donor
  • IHTM14335 · Gifts with reservation (GWRs): the reservation: non-exclusion need not be continuous
  • IHTM14336 · Gifts with reservation (GWRs): the reservation: effect of consideration
  • IHTM14337 · Gifts with reservation (GWRs): the reservation: continuation of reasonable commercial arrangements
  • IHTM14338 · Gifts with reservation (GWRs): the reservation: benefit by associated operations
  • IHTM14339 · Gifts with reservation (GWRs): the reservation: benefit to donor's spouse or civil partner
  • IHTM14340 · Gifts with reservation (GWRs): the reservation: when occupation is not a reservation
  • IHTM14341 · Gifts with reservation (GWRs): the reservation: full consideration in cases of land and chattels
  • IHTM14342 · Gifts with reservation (GWRs): the reservation: infirm relative
  • IHTM14343 · Gifts with reservation (GWRs): the reservation: annual exemption not available
  • IHTM14360 · Gifts with reservation (GWRs): the reservation: interests in land
  • IHTM14371 · Gifts with reservation: tracing: introduction
  • IHTM14372 · Gifts with reservation (GWRs): tracing: absolute gifts of cash
  • IHTM14373 · Gifts with reservation (GWRs): tracing: absolute gifts of property other than cash
  • IHTM14374 · Gifts with reservation (GWRs): tracing: supplementary provisions
  • IHTM14391 · Gifts with reservation (GWRs): settled property: introduction
  • IHTM14392 · Gifts with reservation (GWRs): settled property: reversionary interests
  • IHTM14393 · Gifts with reservation (GWRs): settled property: settlement on discretionary trusts
  • IHTM14394 · Gifts with reservation (GWRs): settled property: donor also a trustee
  • IHTM14395 · Gifts with reservation (GWRs): settled property: reasonable commercial arrangements
  • IHTM14396 · Gifts with reservation (GWRs): settled property: charge to inheritance tax on settled property 
  • IHTM14401 · Gifts with reservation (GWRs): tracing settled property: the property comprised in the gift
  • IHTM14402 · Gifts with reservation (GWRs): tracing settled property: if the property ceases to be settled
  • IHTM14403 · Gifts with reservation (GWRs): tracing settled property: settlement by the donee
  • IHTM14421 · Gifts with reservation (GWRs): insurance policies: introduction
  • IHTM14431 · Gifts with reservation (GWRs): insurance policies: general gifts after 18 March 1986
  • IHTM14432 · Gifts with reservation (GWRs): insurance policies: normal out of income exemption on regular premiums
  • IHTM14433 · Gifts with reservation (GWRs): insurance policies: policies made before 18 March 1986
  • IHTM14434 · Gifts with reservation (GWRs): insurance policies: automatic increases in policy value
  • IHTM14435 · Gifts with reservation (GWRs): insurance policies: change in life assured
  • IHTM14440 · Gifts with reservation (GWRs): insurance policies: the property given
  • IHTM14451 · Gifts with reservation (GWRs): the reservation on insurance policies: introduction
  • IHTM14452 · Gifts with reservation (GWRs): the reservation on insurance policies: special rule for policies with linked benefits
  • IHTM14453 · Gifts with reservation (GWRs): the reservation on insurance policies: reservation examples
  • IHTM14502 · The charge to tax: cumulation
  • IHTM14503 · The charge to tax: cumulation with the death estate
  • IHTM14511 · The charge to tax: potentially exempt transfers (PETs): tax treatment of a PET
  • IHTM14512 · The charge to tax: potentially exempt transfers (PETs): tax treatment of a PET followed by death
  • IHTM14513 · The charge to tax: potentially exempt transfers (PETs): cumulation
  • IHTM14514 · The charge to tax: potentially exempt transfers (PETs): cumulating transfers more than seven years before death
  • IHTM14515 · The charge to tax: potentially exempt transfers (PETs): IHT nil rate band
  • IHTM14516 · The charge to tax: potentially exempt transfers (PETs): rate of tax
  • IHTM14517 · The charge to tax: potentially exempt transfers (PETs): taper relief
  • IHTM14518 · The charge to tax: potentially exempt transfers (PETs): fall in value relief
  • IHTM14519 · The charge to tax: potentially exempt transfers (PETs): special rate
  • IHTM14531 · The charge to tax: immediately chargeable transfers: introduction
  • IHTM14532 · The charge to tax: immediately chargeable transfers: value for tax
  • IHTM14533 · The charge to tax: immediately chargeable transfers: cumulation
  • IHTM14534 · The charge to tax: immediately chargeable transfers: rate of tax
  • IHTM14541 · The charge to tax: grossing: when to gross-up
  • IHTM14542 · The charge to tax: grossing: when not to gross-up
  • IHTM14543 · The charge to tax: grossing: partial grossing
  • IHTM14544 · The charge to tax: grossing: the grossing calculation
  • IHTM14545 · The charge to tax: grossing: tax paid after the death of the transferor
  • IHTM14546 · The charge to tax: grossing: settled property
  • IHTM14547 · The charge to tax: grossing: authority for grossing
  • IHTM14550 · The charge to tax: other charges: late reported transfers
  • IHTM14551 · The charge to tax: other charges: death subsequent to the transfer
  • IHTM14571 · The charge to tax: additional charges: introduction
  • IHTM14572 · The charge to tax: additional charges: value for tax
  • IHTM14573 · The charge to tax: additional charges: cumulation
  • IHTM14574 · The charge to tax: additional charges: rate of tax
  • IHTM14575 · The charge to tax: additional charges: taper relief
  • IHTM14576 · The charge to tax: additional charges: the additional tax payable
  • IHTM14577 · The charge to tax: additional charges: the additional tax payable (example 1)
  • IHTM14578 · The charge to tax: additional charges: the additional tax payable (example 2)
  • IHTM14579 · The charge to tax: reliefs: business relief and agricultural relief
  • IHTM14580 · The charge to tax: reliefs: fall in value relief
  • IHTM14590 · The charge to tax: the charge on lifetime transfers: gifts with reservation (GWRs)
  • IHTM14591 · The charge to tax: the charge on lifetime transfers: simultaneous and same day transfers
  • IHTM14592 · The charge to tax: the charge on lifetime transfers: liability for payment of tax
  • IHTM14593 · The charge to tax: the charge on lifetime transfers: grossing-up the values
  • IHTM14595 · The charge to tax: the charge on lifetime transfers: late reported transfers
  • IHTM14611 · Specific lifetime reliefs: taper relief: when the relief applies
  • IHTM14612 · Specific lifetime reliefs: taper relief: quantifying the relief
  • IHTM14613 · Specific lifetime reliefs: taper relief: period of survival
  • IHTM14621 · Specific lifetime reliefs: fall in value relief: introduction
  • IHTM14622 · Specific lifetime reliefs: fall in value relief: form of the relief
  • IHTM14624 · Specific lifetime reliefs: fall in value relief: conditions for relief
  • IHTM14625 · Specific lifetime reliefs: fall in value relief: what is a qualifying sale?
  • IHTM14626 · Specific lifetime reliefs: fall in value relief: what is market value?
  • IHTM14627 · Specific lifetime reliefs: fall in value relief: the claim
  • IHTM14628 · Specific lifetime reliefs: fall in value relief: wasting assets
  • IHTM14629 · Specific lifetime reliefs: fall in value relief: portfolio of assets
  • IHTM14630 · Specific lifetime reliefs: fall in value relief: more than one sale
  • IHTM14631 · Specific lifetime reliefs: fall in value relief: not all of the transferred assets are sold
  • IHTM14641 · Specific lifetime reliefs: shares and securities: adjustments
  • IHTM14642 · Specific lifetime reliefs: shares and securities: capital receipts
  • IHTM14643 · Specific lifetime reliefs: shares and securities: payment of calls
  • IHTM14644 · Specific lifetime reliefs: shares and securities: changes in shareholdings
  • IHTM14645 · Specific lifetime reliefs: shares and securities: transactions of close companies
  • IHTM14661 · Specific lifetime reliefs: interests in land: changes between transfer and death
  • IHTM14662 · Specific lifetime reliefs: interests in land: changes that have reduced the value
  • IHTM14663 · Specific lifetime reliefs: interests in land: changes that have increased the value
  • IHTM14664 · Specific lifetime reliefs: interests in land: compensation
  • IHTM14670 · Specific lifetime reliefs: interests in land: leases
  • IHTM14671 · Specific lifetime reliefs: interests in land: other property
  • IHTM14691 · Specific lifetime reliefs: double charges relief: when double charges arise
  • IHTM14692 · Specific lifetime reliefs: double charges relief: applying the relief
  • IHTM14693 · Specific lifetime reliefs: double charges relief: authority for the relief
  • IHTM14701 · Specific lifetime reliefs: potentially exempt transfers (PETs): when double charges relief arises
  • IHTM14702 · Specific lifetime reliefs: potentially exempt transfers (PETs): partial consideration
  • IHTM14703 · Specific lifetime reliefs: potentially exempt transfers (PETs): assets representing the asset transferred
  • IHTM14704 · Specific lifetime reliefs: potentially exempt transfers (PETs): calculations
  • IHTM14705 · Specific lifetime reliefs: potentially exempt transfers (PETs): Quick Succession Relief (QSR)
  • IHTM14711 · Specific lifetime reliefs: gifts with reservation (GWRs): when double charges relief arises
  • IHTM14712 · Specific lifetime reliefs: gifts with reservation (GWRs): calculations
  • IHTM14713 · Specific lifetime reliefs: gifts with reservation (GWRs): example of calculations 1
  • IHTM14714 · Specific lifetime reliefs: gifts with reservation (GWRs): example of calculations 2
  • IHTM14721 · Specific lifetime reliefs: disallowed debts: when double charges relief arises
  • IHTM14722 · Specific lifetime reliefs: disallowed debts: calculations
  • IHTM14730 · Specific lifetime reliefs: disallowed debts: transfers chargeable when made
  • IHTM14731 · Specific lifetime reliefs: disallowed debts: calculations producing the same amount
  • IHTM14732 · Specific lifetime reliefs: disallowed debts: discretionary trusts
  • IHTM14802 · Omissions: possible omissions of lifetime transfers
  • IHTM14810 · Omissions: omission to exercise a right
  • IHTM14821 · Associated operations: why are the provisions necessary?
  • IHTM14822 · Associated operations: definition
  • IHTM14823 · Associated operations: the objective test
  • IHTM14824 · Associated operations: the subjective test
  • IHTM14825 · Associated operations: additional provisions
  • IHTM14826 · Associated operations: definition of terms
  • IHTM14827 · Associated operations: transfer of value made by associated operations
  • IHTM14828 · Associated operations: restrictions on which operations can be taken into account
  • IHTM14829 · Associated operations: Re Macpherson
  • IHTM14830 · Associated operations: insurance policies
  • IHTM14831 · Associated operations: gifts with reservation (GWRs)
  • IHTM14832 · Associated operations: transfers involving relievable property
  • IHTM14833 · Associated operations: gifts between spouses or civil partners
  • IHTM14834 · Associated operations: sale without immediate payment of the purchase price
  • IHTM14835 · Associated operations: transfer in stages
  • IHTM14836 · Associated operations: successive settlements
  • IHTM14851 · Transfers by close companies: introduction
  • IHTM14852 · Transfers by close companies: transfers of value
  • IHTM14853 · Transfers by close companies: exemptions
  • IHTM14854 · Transfers by close companies: foreign aspects
  • IHTM14855 · Transfers by close companies: alterations in share capital, loan capital or rights
  • IHTM14856 · Transfers by close companies: liability to tax
  • IHTM14871 · Future payments: introduction
  • IHTM14872 · Future payments: calculating the chargeable portion
  • IHTM14873 · Future payments: exemptions
  • IHTM14874 · Future payments: payments outstanding at death
  • IHTM14881 · Dating of dispositions: introduction
  • IHTM14882 · Dating of dispositions: gifts by cheque
  • IHTM14883 · Dating of dispositions: dispositions affecting land
  • IHTM14884 · Dating of dispositions: chattels and corporeal moveables
  • IHTM14885 · Dating of dispositions: choses in action and incorporeal moveables
  • IHTM14890 · Investigation issues: voidable transfers
  • IHTM14900 · Investigation issues: donatio mortis causa (DMC)
  1. Lifetime transfers: contents
  2. Lifetime transfers: gifts in consideration of marriage or registration of civil partnership: summary

IHTM14191 | Lifetime transfers: gifts in consideration of marriage or registration of civil partnership: summary

From HM Revenue & Customs · Inheritance Tax Manual

Under IHTA84/S22 a gift will be exempt up to the limits set out below if it was made

  • on or shortly before a marriage or the registration of civil partnership (IHTM11032) takes place,

  • to one or both parties to the marriage or civil partnership, and

  • to become fully effective when the marriage or registration of civil partnership takes place.

The limits of the exemption for the transferor (regardless of whether the transfer is to both parties to the marriage or only one) are

  • £5,000 if they are a parent of one party to the marriage or civil partnership,

  • £2,500 if they are either a remoter ancestor than a parent of a party to the marriage or civil partnership, or are one of the parties to the intended marriage or civil partnership,

  • £1,000 in any other case.

If the value transferred by the gift is more than the amount of the available exemption, it is an exempt transfer up to the amount of the available exemption, and the excess is chargeable.

The exemption can apply to:

  • lifetime transfers by individuals (IHTM04053) and

  • the lifetime termination of an interest in possession (IHTM16061) in settled property.

The exemption does not apply to

  • the deemed potentially exempt transfer (IHTM04064) under FA64/S102 (4) and FA86/S103 (5)

  • apportionments made to persons under IHTA84/S94 (transfers by close companies (IHTM14851)).

The part of the transfer which is exempt under the marriage or civil partnership exemption (IHTM11032) cannot be taxed under the gift with reservation (IHTM04071) rules.

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