IHTM30211 | Transfers on death: introduction

From HM Revenue & Customs · Inheritance Tax Manual

Instalments are available for chargeable transfers made on death for the tax attributable to the value, including any addition for grossing up (), of certain categories of qualifying property ().

By reason of , the transfer on death includes property taxable as a gift with reservation (GWR) () because it was subject to a reservation at the death of the donor. However, because GWRs involve a lifetime gift, the application of the instalment provisions to them () needs separate consideration.