IHTM24200 | Gifts with reservation of benefit: Introduction

From HM Revenue & Customs · Inheritance Tax Manual

A gift with reservation of benefit (GWR) () charge arises on either

  • the death of the donor (the person who made the GWR), or

  • the release of the reservation by the donor.

The conditions for agricultural relief on property charged as a GWR depends on whether the property is

  • land or buildings to which applies (), or

  • shares or securities in a company to whichIHTA84/S122 (1) applies ().

If the property charged is shares or securities in a company with agricultural assets to which does not apply, then agricultural relief will not be due but business relief may be relevant ().