Gifts with reservation 鈥� further provisions
Trusts and Inheritance Tax
Guidance
Introduction
This guidance note looks at the specific gifts with reservation rules regarding:
- 鈥�
agricultural and business property
- 鈥�
substitutions and accretions
These additional rules are to be found in FA 1986, Sch 20.
It also considers the gift with reservation (GWR) consequences when a person redirects property he has inherited under an instrument of variation.
Agricultural property relief (APR) and business property relief (BPR)
Special rules apply where a donor reserves a benefit in a gift which qualifies for BPR or APR. The availability of those reliefs depends on:
- 鈥�
the character of the property given
- 鈥�
the nature and extent of the ownership
- 鈥�
the duration of ownership and occupation
All the relevant conditions are set out in the Agricultural property relief (APR) and BPR overview guidance notes.
Where a donor makes a gift which qualifies for APR or BPR, and he reserves a benefit in it, it will be necessary to determine whether the property still qualifies for APR or BPR when
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