IHTM25382 - Gifts with reservation: Notional transfer

For the purpose of deciding whether the asset qualifies for business relief on the notional transfer by the donee at the time of the GWR charge

  • treat any period of ownership by the donor prior to the gift as ownership by the donee for the purposes of the ownership test (IHTM25301), FA86/SCH20/para8 (2) (a) , and
  • if the donee dies before the time of the GWR charge, for the period after the donee바카라 사이트™s death treat the donee바카라 사이트™s personal representatives or beneficiaries of the GWR property as the donee, FA86/SCH20/para8

Note that if the GWR charge arises on the release of the reservation, the transferor is treated as making a PET (IHTM04057) and the additional conditions for lifetime transfers (IHTM25361) will also need to be satisfied at the date of death.