IHTM30084 | Liability on gifts with reservation (GWRs): definition and extent of liability
From HM Revenue & Customs · Inheritance Tax Manual
Persons liable under
These are the same as for other transfers on death ().
Personal representatives of the deceased
The instructions relating to the secondary liability of the personal representatives () of the transferor for tax on a potentially exempt transfer () apply. The limitation () in applies.
Trustees
Trustees will normally be liable as persons in whom property is vested under . There are limitations () on their liability.
Recipients of benefit from settled property ()
The limitation () in applies.