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To prevent IHT being paid twice on the same value where a transferor has received back property previously given away, relief is given in some circumstances by the IHT (Double Charges Relief) Regulations 1987¹. See I3.556 for the general background to these regulations, and for possible instances of double charging for which they give no relief. There is a similar relief given by IHT (Double Charges Relief) Regulations 2005² for cases where IHT avoidance schemes have been unscrambled to avoid paying the pre-owned assets charge.

This article deals first with reg 4 of the 1987 Regulations, which concerns transactions such as the following. A gives property to B by a potentially exempt transfer (PET). B then gives the property (or property directly or indirectly representing it) back to A otherwise than for full consideration in money or money's worth, or dies having left it to A.

A dies within seven years of the original transfer to B, so that it becomes a chargeable transfer, and the property given back by B forms part