»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýapp exemption is subject to the same exclusions (IHTM11171) that apply to charity exemption (IHTM11101), but with certain qualifications under IHTA84/S25 (2) which allow exemption that would otherwise be excluded. »Ê¹ÚÌåÓýapp situations where IHTA84/S25 (2) applies to allow the exemption are:

• the IHTA84/S23 (3) exclusion of gifts of less than the donor’s whole interest or for a limited period (IHTM11176) does not prevent the IHTA84/S25 (1) exemption from applying to property consisting of the benefit of an agreement restricting the use of land
• gifts of land to the National Trust may be accompanied by a memorandum of wishes under which the donor or other person is permitted to reside in the house and receive the rent during their lifetime. »Ê¹ÚÌåÓýapp memorandum has no legal force and the reservation, no matter for whose benefit, does not prevent exemption under IHTA84/S25 from applying.