Relief under IHTA84/Sch6/para3 (1) is available on reversions purchased or mortgaged for full consideration in money or money's worth before 27 March 1974.

Where the original purchase of the reversion was exempt by reason of purchase for full consideration – FA1894/S3 – then the Estate Duty (ED) would have been nil. Accordingly, the taxpayable on the death of the life tenant remains at nil, because of IHTA84/Sch6/para3 (1).

There is no relief for partial consideration.

Form of the relief

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