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Taper Relief and Lifetime Gifts: Technical Analysis for Tax Advisors

· 21 min

Executive Summary

Taper relief under IHTA 1984 s.7(4) is among the most widely misunderstood provisions in inheritance tax planning. The relief reduces the tax charged on a chargeable transfer, not the capital value of the transfer itself, and delivers no benefit where cumulative lifetime gifts remain within the nil-rate band of GBP 325,000.12 With IHT receipts reaching GBP 8.2 billion in 2024-25 and the nil-rate band frozen until 2030-31, more estates are exposed to IHT charges on lifetime gifts that fail the seven-year survival test.34 The April 2026 APR/BPR reforms introduce transitional rules affecting lifetime gifts of qualifying property made on or after 30 October 2024, increasing the IHT exposure against which taper relief operates.5 This article provides a forensic analysis of taper relief mechanics, cumulation principles, the 14-year lookback, gifts with reservation, and the CGT cost of lifetime transfers, equipping tax advisors to model taper relief outcomes with technical precision.

1. The Taper Relief Misconception

IHT receipts have reached levels that demand precision in lifetime gift planning. HMRC collected a record GBP 8.2 billion in 2024-25, with GBP 7.1 billion in the first ten months of 2025-26 alone.36 The Office for Budget Responsibility forecasts receipts of GBP 14.5 billion by 2030-31.7 The nil-rate band, frozen at GBP 325,000 since 2009-10 and now confirmed frozen through 2030-31, continues to draw more estates into the IHT net through fiscal drag.4 In 2022-23, 31,500 estates -- 4.62% of UK deaths -- incurred IHT charges, with average tax per estate of GBP 212,000 and total liabilities of GBP 6.70 billion.8

Against this backdrop, taper relief is frequently presented as a planning benefit of lifetime gifting: the longer the donor survives beyond three years, the lower the IHT charge. This framing is misleading. The statutory position under IHTA 1984 s.7(4) is that taper relief operates as a percentage reduction of the tax rate applied to a chargeable transfer, not a reduction of the transfer value.12 The taper percentages reduce the proportion of the full death rate charged:

Years Between Transfer and Death Percentage of Full Death Rate Charged
0-3 years 100%
3-4 years 80%
4-5 years 60%
5-6 years 40%
6-7 years 20%

Applying these to the standard 40% death rate produces effective rates of 32%, 24%, 16%, and 8% respectively.9 The critical constraint is this: if the cumulative value of chargeable transfers in the seven years before death does not exceed the nil-rate band, there is no tax to which taper relief can apply.210 The relief delivers nothing. This "no tax, no taper" principle is the central technical reality that practitioners must communicate to clients who assume that any gift surviving three years receives automatic IHT reduction.

2. Potentially Exempt Transfers and the Exemption Framework

2.1 The Seven-Year Rule

A potentially exempt transfer under IHTA 1984 s.3A is a transfer of value made by an individual to another individual (or to certain specified trusts) that is assumed exempt during the transferor's lifetime.11 If the transferor survives seven years, the PET becomes a fully exempt transfer. If death occurs within seven years, the PET becomes chargeable -- a "failed PET" -- and tax is calculated at the full death rate, subject to taper relief where applicable.10

Transfers that cannot qualify as PETs include gifts into relevant property (discretionary) trusts, which are immediately chargeable lifetime transfers, and deemed dispositions on alteration of close company share rights.12 The distinction between PETs and chargeable lifetime transfers is fundamental to the taper relief analysis, as each category follows different computational mechanics on death within seven years.

2.2 Exemptions That Remove Gifts from Cumulation

Several statutory exemptions reduce or eliminate the chargeable value of lifetime transfers before cumulation principles apply. The annual exemption under IHTA 1984 s.19 permits GBP 3,000 per tax year, with any unused portion carrying forward for one year only.13 The small gifts exemption under s.20 provides GBP 250 per donee per tax year, though this cannot be combined with the annual exemption for the same recipient.14 Marriage or civil partnership gifts under s.22 are exempt up to GBP 5,000 from a parent, GBP 2,500 from a grandparent or remoter ancestor, and GBP 1,000 from any other person.15

The normal expenditure out of income exemption under IHTA 1984 s.21 is uncapped and potentially the most significant exemption in practice.16 Three conditions must be satisfied per the leading authority of Bennett v IRC [1995] STC 54: the gift must form part of the transferor's normal expenditure, it must be made out of income (not capital), and the transferor's standard of living must not diminish.1718 Gifts qualifying under s.21 are wholly exempt and never enter the cumulation calculation. The annual exemption is applied last after all other exemptions, per IHTM14132.19

The planning significance is direct: gifts falling within these exemptions reduce the chargeable amount that enters cumulation, thereby preserving more of the nil-rate band for larger transfers. Where cumulation is managed effectively through exemptions, taper relief becomes unnecessary because no tax arises on the remaining chargeable transfers.

3. Cumulation: The Mechanism Determining Taper Relief Outcomes

3.1 The Seven-Year Cumulation Principle

Tax on any chargeable transfer is calculated by cumulating the values of all chargeable transfers made in the seven years preceding it.20 The cumulative total determines how much of the nil-rate band has been consumed by prior transfers. Gifts falling more than seven years before the relevant transfer drop out of cumulation.21 On death, chargeable lifetime transfers in the preceding seven years cumulate against the death estate, with gifts always using the nil-rate band before the death estate.2223

3.2 Worked Example A: Taper Relief Delivers No Benefit

A donor makes a PET of GBP 200,000 (net of annual exemption) and dies five years later with no other chargeable transfers in the preceding seven years. The cumulative total is GBP 200,000, which is below the GBP 325,000 nil-rate band. IHT on the failed PET: nil. Taper relief at the 40% rate (five-to-six-year band) applies to GBP nil of tax. The taper saving is zero. The gift was always covered by the nil-rate band, and taper relief is irrelevant.2

This scenario applies to the majority of estates making lifetime gifts. Where the total chargeable transfers in the seven years before death remain within the nil-rate band, taper relief provides no benefit regardless of the survival period. The nil-rate band has remained at GBP 325,000 since 2009-10, and the confirmed freeze through 2030-31 means that this threshold will have been unchanged for over two decades.4 Practitioners should model the cumulation position for every client before advising on the potential benefit of taper relief.

3.3 Worked Example B: Taper Relief Provides a Measurable Benefit

A donor makes a PET of GBP 450,000 (net of exemptions) with no other chargeable transfers, and dies four years and six months later. The amount exceeding the nil-rate band is GBP 125,000 (GBP 450,000 less GBP 325,000). IHT at the full 40% death rate: GBP 50,000. Taper relief for the four-to-five-year band reduces the rate to 60% of 40% = 24%. Tapered IHT: GBP 30,000. The taper saving is GBP 20,000.9

Taper relief delivers value only on the tax attributable to the portion of cumulative gifts exceeding the nil-rate band. A GBP 450,000 gift generates a taper saving of GBP 20,000 -- 4.4% of the gift value. Presenting this as a substantial planning benefit, without reference to the cumulation threshold, risks materially overstating its significance. The benefit scales with the size of the excess above the nil-rate band: a GBP 1 million PET with death at the same point would generate taper relief of GBP 108,000 (24% versus 40% on GBP 675,000), a more material outcome.

3.4 The 14-Year Lookback

The interaction between PETs and prior chargeable lifetime transfers creates a lookback period extending to 14 years before death.2421 A CLT made more than seven years before death falls outside the death charge, but if it falls within seven years of a failed PET, it cumulates against that PET, reducing the nil-rate band available.

Worked Example C: A donor made a GBP 200,000 CLT into a discretionary trust nine years before death, then a GBP 300,000 PET five years before death. The CLT is more than seven years before death (no death charge on the CLT itself), but it is within seven years of the PET. The CLT cumulates against the PET: nil-rate band available to the PET is GBP 125,000 (GBP 325,000 less GBP 200,000). The chargeable amount above the nil-rate band is GBP 175,000. IHT at the full death rate: GBP 70,000. Tapered at 40% (five-to-six-year band): GBP 28,000.24

Had the CLT not existed, the PET would have been fully within the nil-rate band with no tax and no taper benefit needed. The 14-year lookback fundamentally changes the taper relief calculation. Practitioners advising clients with historic trust arrangements must trace chargeable transfer histories back up to 14 years from the anticipated death date to identify CLTs that reduce the available nil-rate band for subsequent PETs.

4. Taper Relief on Chargeable Lifetime Transfers

4.1 The Lifetime Charge and Death Recalculation

Gifts into discretionary trusts are immediately chargeable at the lifetime rate of 20% (half the death rate) on the value exceeding the available nil-rate band after cumulation.12 If the donor dies within seven years, the CLT is recalculated at the full 40% death rate, with credit given for lifetime tax already paid.25

Taper relief applies to the recalculated tax where the CLT was made more than three years before death.25 However, IHTA 1984 s.7 imposes a floor: the effective tapered rate cannot fall below the original lifetime rate of 20%.1 This floor materially limits the taper relief benefit for CLTs compared to PETs, where no lifetime tax was paid and the floor does not constrain the calculation.

4.2 Worked Example D: The CLT Floor Provision

A donor makes a GBP 500,000 CLT into a discretionary trust with GBP 325,000 nil-rate band available. Lifetime tax at 20% on GBP 175,000: GBP 35,000 (paid by the trustees). The donor dies five years and six months later.

Recalculated tax at 40%: GBP 70,000. Taper relief for the five-to-six-year band: 40% of 40% = 16%. Tapered tax: GBP 28,000. However, the floor provision applies: 16% is below the 20% lifetime rate. The effective rate is therefore capped at 20%, producing tax of GBP 35,000. Credit for lifetime tax paid: GBP 35,000. Additional charge: nil.125

The floor provision means that for CLTs where the donor dies between five and seven years after the transfer, taper relief cannot reduce the effective rate below the lifetime rate already charged. The additional tax benefit of taper relief on CLTs is therefore confined to deaths occurring between three and approximately five years after the transfer, where the tapered rate (32% or 24%) still exceeds the 20% floor. Where the donor pays the lifetime tax (rather than the trustees), grossing up applies, increasing the effective transfer value and the subsequent death recalculation. Practitioners should verify whether the donor or the trustees bore the original lifetime charge when modelling the additional charge on death.

5. Gifts with Reservation: The Taper Relief Defeater

5.1 The Statutory Framework

FA 1986 s.102 provides that property subject to a reservation of benefit is treated as part of the donor's estate immediately before death.26 A gift with reservation arises where the donee does not assume bona fide possession and enjoyment of the property, or the property is not enjoyed to the entire exclusion of the donor and of any benefit to the donor by contract or otherwise.27

Where the reservation continues to death, the property is treated as if the donor were beneficially entitled to it at death. The gift is not a PET, the seven-year rule does not apply, and taper relief is wholly unavailable.26 If the reservation ceases before death, the donor is treated as making a PET at the date of cessation, not the original gift date. The seven-year clock restarts from cessation.26

5.2 Double Charges Relief

The Inheritance Tax (Double Charges Relief) Regulations 1987 (SI 1987/1130) prevent double taxation where property is simultaneously a failed PET (because the reservation ceased within seven years of death) and included in the estate as a gift with reservation.28 The Regulations compare two alternative calculations and apply the method producing the higher tax. Taper relief, as defined in the Regulations by reference to s.7(4), operates within the failed PET calculation but does not "rescue" the GWR treatment.28

5.3 Common Traps

The most frequent GWR failure in practice involves property gifts where the donor continues to reside in or benefit from the gifted property. A parent who gifts a residential property to adult children but continues to live in it rent-free creates a GWR. If the parent pays a full market rent, FA 1986 s.102B provides an exception, but the rent must genuinely reflect market value and be regularly reviewed.26 Similarly, gifts of funds where the donor retains access to the bank account, or gifts of investment portfolios where the donor continues to receive income, may constitute reservations. Advisors should conduct a thorough reservation of benefit analysis at the point of any gift and document the conclusion in the client file, as HMRC may scrutinise the arrangement years later during the IHT compliance process.

Pre-owned assets tax under FA 2004 Schedule 15 applies as an income tax charge where arrangements circumvent the GWR rules without falling squarely within them.29 An election to be treated as making a GWR avoids the POAT income tax charge but brings the property back within the estate for IHT purposes, negating any taper relief planning. The POAT regime operates as a backstop to the GWR rules, targeting arrangements such as the "Eversden" and "Ingram" schemes that attempted to separate the benefit retained from the property given away.

6. The April 2026 Convergence: APR/BPR Transitional Rules and Taper Relief

The APR/BPR reforms from 6 April 2026 introduce a combined allowance of GBP 2.5 million for 100% relief, with 50% relief applying on qualifying assets above that threshold, producing an effective IHT rate of 20%.5 AIM-listed shares receive 50% relief only and are excluded from the GBP 2.5 million allowance.5 The allowance refreshes every seven years for individuals and every ten years for trusts.30

The transitional rules are critical to the taper relief interaction. New relief rates apply to lifetime transfers of qualifying APR/BPR property made on or after 30 October 2024 where the donor dies on or after 6 April 2026.531 Lifetime transfers of qualifying property made before 30 October 2024 are subject to the old (unlimited) relief rates regardless of the donor's death date.531

The practical consequence is this: a failed PET of qualifying agricultural or business property where the donor made the gift on or after 30 October 2024 and dies after 6 April 2026 will have the capped relief rates applied first, potentially generating a significantly higher IHT charge than under the previous regime. Taper relief then operates on this larger tax amount. Where previously a GBP 4 million farm might have attracted 100% APR with no IHT charge (and therefore no taper relief needed), the same gift under the new rules would attract 100% relief on GBP 2.5 million and 50% relief on GBP 1.5 million, producing a taxable amount of GBP 750,000 and IHT of GBP 300,000 before taper.5

Advisors should urgently review any lifetime gifts of qualifying property made since 30 October 2024 to model the taper relief exposure. The interaction between the residence-based IHT regime enacted from 6 April 2025 and these transitional rules adds further complexity for internationally mobile clients, where the settlor's long-term UK resident status determines whether excluded property treatment applies to trust assets.32 Under the new regime, an individual is a long-term UK resident for IHT purposes if UK tax resident for at least 10 of the previous 20 tax years, with an IHT tail of 3 to 10 years following departure depending on the duration of prior residence.32 Pension death benefits are legislated to enter the IHT estate from April 2027, which is expected to further increase estate values against which cumulation and taper relief must be assessed; detailed implementation regulations had not been published as of 26 February 2026, and practitioners should monitor HMRC guidance for operational details.

7. The CGT Cost of Lifetime Gifts: The Taper Relief Trade-Off

7.1 The Triple Tax Exposure

Lifetime gifts of chargeable assets constitute disposals at market value for CGT purposes.33 CGT rates for 2025-26 are 18% (basic rate) and 24% (higher rate), with Business Asset Disposal Relief at 14%, rising to 18% from 6 April 2026.34 On death, assets receive a full CGT base cost uplift to market value, eliminating any accrued gain.35

The "triple whammy" arises where a donor gifts an appreciated asset, pays CGT on the disposal, dies within seven years triggering IHT on the failed PET (with limited taper relief), and forfeits the CGT base cost uplift that death would have provided. The CGT paid is an irrecoverable sunk cost regardless of the IHT outcome.

7.2 Worked Example E: Quantifying the Trade-Off

A business owner gifts GBP 600,000 of unquoted trading company shares (base cost GBP 100,000) in January 2026, claiming BADR at 14%. CGT: GBP 70,000 (14% on GBP 500,000 gain). The shares form part of a holding exceeding the GBP 2.5 million combined APR/BPR allowance, and under the post-April 2026 regime, the shares above the allowance attract only 50% BPR, leaving a material IHT exposure. The donor's cumulative chargeable transfers exceed the nil-rate band.

Scenario 1 -- Donor survives seven years: CGT paid: GBP 70,000. IHT: nil (PET fully exempt). Total tax: GBP 70,000. Compared to retention until death: IHT at 40% on GBP 600,000 less 50% BPR on the excess above the allowance. Net saving from gifting: substantial, though dependent on the overall BPR position.

Scenario 2 -- Donor dies after five years: CGT paid: GBP 70,000. IHT on failed PET at tapered rate (60% of 40% = 24%) on the portion exceeding available reliefs and the nil-rate band: GBP 144,000 on GBP 600,000 assuming full exposure. Total tax: GBP 214,000. Compare to death retention with partial BPR: the net saving from gifting with taper narrows considerably.

Scenario 3 -- Donor dies after two years: CGT paid: GBP 70,000. IHT at full 40%: GBP 240,000. Death uplift lost. Total tax: GBP 310,000. Retention would have cost GBP 240,000 IHT (assuming identical BPR position). Net detriment from gifting: GBP 70,000.

The critical planning point is that gifting BPR-qualifying assets became materially more complex following the April 2026 reforms. Where holdings exceed the GBP 2.5 million allowance, the partial loss of relief creates an IHT exposure that taper relief can mitigate but not eliminate, and the upfront CGT cost must be weighed against a probability-weighted IHT saving that is no longer binary (full relief versus no relief).

Hold-over relief under TCGA 1992 s.165 is available for business assets, deferring the CGT until the donee disposes of the asset.36 Where available, hold-over relief eliminates the upfront CGT cost, making the gift strategy more robust against early death. However, the donee inherits the low base cost, creating a future CGT exposure that must be factored into the overall family tax position.

7.3 Risk Mitigation: Gift Inter Vivos Insurance

Decreasing term assurance, commonly termed gift inter vivos insurance, provides a practical mechanism to cover the potential IHT charge during the seven-year PET period. The sum assured decreases in line with the taper relief schedule, matching the reducing IHT exposure over time. Premiums are typically modest for healthy donors and may themselves qualify as normal expenditure out of income under IHTA 1984 s.21, provided the three Bennett conditions are met.1617 Advisors should note that arranging such policies falls within the FCA regulatory perimeter, requiring appropriate authorisation or referral to a suitably regulated intermediary.

8. Reporting Obligations

Reporting requirements differ by gift type and must be mapped to each transfer in the client's history. Failed PETs are reported on Form IHT403, which accompanies the IHT400 death estate return and requires details of all gifts and transfers of value.37 Immediately chargeable lifetime transfers (CLTs into trust) are reported on Form IHT100a, which was updated in April 2025 to reflect the residence-based IHT regime.38 IHT100a is not used for failed PETs on death; these are captured exclusively through IHT403.38 Discretionary trusts receiving CLTs must register with the Trust Registration Service within 90 days of the chargeable event.39

Practitioners should ensure that contemporaneous records of all lifetime gifts are maintained, including valuations at the date of transfer, exemption claims (particularly annual exemption utilisation and normal expenditure evidence), and details of any reservation of benefit analysis undertaken at the time of the gift. Robust record-keeping is essential because the IHT compliance process may not arise until many years after the gift was made, and the burden of establishing exemption claims and the absence of reservation falls on the taxpayer.

Conclusion

Taper relief is a conditional consequence of surviving a lifetime gift, not a planning strategy in its own right. The "no tax, no taper" principle means that for the majority of estates where cumulative lifetime gifts remain within the nil-rate band, taper relief is entirely irrelevant. Where it does apply, the benefit is confined to the tax on the excess above the nil-rate band, and the CLT floor provision further limits savings for trust gifts.

The April 2026 APR/BPR reforms heighten the stakes: transitional rules for gifts of qualifying property made on or after 30 October 2024 may generate materially higher IHT charges on early death, increasing both the potential taper relief amount and the exposure to the triple whammy of CGT, IHT, and lost death uplift. The residence-based IHT regime enacted from 6 April 2025 adds a further dimension for internationally mobile clients whose long-term UK resident status determines excluded property treatment.

A rigorous advisory approach requires: modelling cumulation before recommending any gifting strategy; assessing the CGT cost against the probability-weighted IHT saving; verifying the absence of any reservation of benefit; tracing the 14-year lookback for clients with historic trust arrangements; reviewing APR/BPR transitional exposure for qualifying property gifts; and considering gift inter vivos insurance where the IHT exposure justifies the premium cost. Form IHT403 (for PETs) and IHT100a (for CLTs) impose distinct reporting obligations that practitioners must map to each gift in the client's transfer history.

CPD Declaration

Estimated Reading Time: 18 minutes Technical Level: Advanced Practice Areas: Inheritance tax planning, lifetime gift structuring, CGT/IHT integration, trust taxation

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the conditions under which IHT taper relief under IHTA 1984 s.7(4) applies and the circumstances in which it delivers no benefit
  2. Apply the seven-year cumulation principle to determine the available nil-rate band for a sequence of lifetime gifts including PETs and CLTs
  3. Analyse the interaction between taper relief and the APR/BPR transitional rules for gifts of qualifying property made on or after 30 October 2024
  4. Evaluate the CGT cost of lifetime gifting against the potential IHT saving, accounting for taper relief, the CLT floor provision, and the death CGT base cost uplift

Competency Mapping

  • ATT Competency: Inheritance tax -- lifetime transfers, cumulation, and reliefs
  • CTA Competency: Advanced IHT planning -- interaction of CGT, IHT, and trust taxation
  • SRA Competence Statement: A4 -- Draw on knowledge to identify issues, and apply sound judgement to those issues

Reflective Questions

  1. How would a comprehensive cumulation analysis change the gift planning advice provided to clients with historic CLTs into trust?
  2. What additional due diligence steps should be implemented to verify the absence of reservation of benefit before relying on taper relief in a gift planning strategy?
  3. How should the APR/BPR transitional rules influence the timing recommendations for clients considering lifetime transfers of qualifying agricultural or business property?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 26 February 2026. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. Inheritance Tax Act 1984 Section 7 (Rates). https://www.legislation.gov.uk/ukpga/1984/51/section/7 ↩ ↩2 ↩3 ↩4

  2. HMRC Inheritance Tax Manual IHTM14611: Taper relief -- when the relief applies. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14611 ↩ ↩2 ↩3 ↩4

  3. HMRC Tax Receipts and National Insurance Contributions Monthly Bulletin. https://www.gov.uk/government/statistics/hmrc-tax-and-nics-receipts-for-the-uk/hmrc-tax-receipts-and-national-insurance-contributions-for-the-uk-new-monthly-bulletin ↩ ↩2

  4. GOV.UK: Inheritance Tax thresholds. https://www.gov.uk/government/publications/inheritance-tax-thresholds/inheritance-tax-thresholds ↩ ↩2 ↩3

  5. GOV.UK: Agricultural property relief and business property relief changes. https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  6. HMRC Tax Receipts Monthly Bulletin (January 2026). https://www.gov.uk/government/statistics/hmrc-tax-and-nics-receipts-for-the-uk/hmrc-tax-receipts-and-national-insurance-contributions-for-the-uk-new-monthly-bulletin ↩

  7. GOV.UK: Budget 2025 document. https://www.gov.uk/government/publications/budget-2025-document/budget-2025-html ↩

  8. HMRC Inheritance Tax Liabilities Statistics Commentary (July 2025). https://www.gov.uk/government/statistics/inheritance-tax-liabilities-statistics/inheritance-tax-liabilities-statistics-commentary ↩

  9. HMRC Inheritance Tax Manual IHTM14612: Taper relief -- quantifying the relief. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14612 ↩ ↩2

  10. HMRC Inheritance Tax Manual IHTM14517: PETs -- taper relief. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14517 ↩ ↩2

  11. Inheritance Tax Act 1984 Section 3A (Potentially exempt transfers). https://www.legislation.gov.uk/ukpga/1984/51/section/3A ↩

  12. HMRC Inheritance Tax Manual IHTM04067: What is an immediately chargeable transfer? https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm04067 ↩ ↩2

  13. Inheritance Tax Act 1984 Section 19 (Annual exemption). https://www.legislation.gov.uk/ukpga/1984/51/section/19 ↩

  14. Inheritance Tax Act 1984 Section 20 (Small gifts). https://www.legislation.gov.uk/ukpga/1984/51/section/20 ↩

  15. Inheritance Tax Act 1984 Section 22 (Gifts in consideration of marriage or civil partnership). https://www.legislation.gov.uk/ukpga/1984/51/section/22 ↩

  16. HMRC Inheritance Tax Manual IHTM14231: Normal expenditure out of income -- introduction. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14231 ↩ ↩2

  17. HMRC Inheritance Tax Manual IHTM14244: Normal expenditure -- Bennett v IRC. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14244 ↩ ↩2

  18. HMRC Inheritance Tax Manual IHTM14255: Normal expenditure -- transferor's standard of living. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14255 ↩

  19. HMRC Inheritance Tax Manual IHTM14132: Order in which exemptions apply. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14132 ↩

  20. HMRC Inheritance Tax Manual IHTM14502: Cumulation. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14502 ↩

  21. HMRC Inheritance Tax Manual IHTM14513: PETs -- cumulation. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14513 ↩ ↩2

  22. HMRC Inheritance Tax Manual IHTM14503: Cumulation with the death estate. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14503 ↩

  23. GOV.UK: Work out Inheritance Tax due on gifts. https://www.gov.uk/guidance/work-out-inheritance-tax-due-on-gifts ↩

  24. HMRC Inheritance Tax Manual IHTM14514: PETs -- cumulating transfers more than seven years before death. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14514 ↩ ↩2

  25. HMRC Inheritance Tax Manual IHTM14575: Additional charges -- taper relief. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14575 ↩ ↩2 ↩3

  26. Finance Act 1986 Section 102 (Gifts with reservation). https://www.legislation.gov.uk/ukpga/1986/41/section/102 ↩ ↩2 ↩3 ↩4

  27. HMRC Inheritance Tax Manual IHTM14301: Gifts with reservation -- requirements for a GWR. https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm14301 ↩

  28. The Inheritance Tax (Double Charges Relief) Regulations 1987 (SI 1987/1130). https://www.legislation.gov.uk/uksi/1987/1130/schedule/made ↩ ↩2

  29. Finance Act 2004 Schedule 15 (Charge to income tax on benefits received by former owner of property). https://www.legislation.gov.uk/ukpga/2004/12/schedule/15 ↩

  30. GOV.UK: Reforms to IHT agricultural property relief and business property relief -- application in relation to trusts. https://www.gov.uk/government/consultations/reforms-to-inheritance-tax-reliefs-consultation-on-property-settled-into-trust/reforms-to-inheritance-tax-agricultural-property-relief-and-business-property-relief-application-in-relation-to-trusts ↩

  31. AccountingWEB: How transitional rules on IHT reliefs affect gifts. https://www.accountingweb.co.uk/tax/hmrc-policy/how-transitional-rules-on-iht-reliefs-affect-gifts ↩ ↩2

  32. GOV.UK: Inheritance Tax if you're a long-term UK resident. https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident ↩ ↩2

  33. HMRC Capital Gains Manual CG36300. https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg36300 ↩

  34. GOV.UK: Capital Gains Tax rates and allowances. https://www.gov.uk/guidance/capital-gains-tax-rates-and-allowances ↩

  35. GOV.UK: HS282 Death, personal representatives and legatees (2025). https://www.gov.uk/government/publications/death-personal-representatives-and-legatees-hs282-self-assessment-helpsheet/hs282-death-personal-representatives-and-legatees-2025 ↩

  36. Taxation of Chargeable Gains Act 1992 Section 165. https://www.legislation.gov.uk/ukpga/1992/12/section/165 ↩

  37. GOV.UK: Inheritance Tax -- gifts and other transfers of value (IHT403). https://www.gov.uk/government/publications/inheritance-tax-gifts-and-other-transfers-of-value-iht403 ↩

  38. GOV.UK: Tell HMRC about a gift or other transfers of value in a trust (IHT100a). https://www.gov.uk/government/publications/inheritance-tax-gifts-and-other-transfers-of-value-iht100a ↩ ↩2

  39. HMRC Trust Registration Service Manual TRSM10020. https://www.gov.uk/hmrc-internal-manuals/trust-registration-service-manual/trsm10020 ↩

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