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Chapter IHTM24202

Document Cited authorities 1 Cited in Related
Vincent
Published date20 March 2016
Record NumberIHTM24202
CourtHM Revenue & Customs

Whether the property is agricultural property (IHTM24030) at the time of the GWR charge (IHTM24200) will depend on whether the charge arises on the death of the donor, FA86/S102 (3), or when the reservation ceases, FA86/S102 (4).

For charges on the death of the donor

  • the property is treated as part of the deceased’s estate immediately before the death, so you can decide whether it is agricultural property within the meaning of IHTA84/S115 (2) by reference to the assets in the deceased’s death estate (IHTM04029) as a whole.

For charges on the release of the reservation

  • the donor is treated as having made a PET (IHTM04064). The availability of relief must be determined on the basis of...

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