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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: what is the value transferred by a gift with reservation of benefit?

The value transferred (IHTM04028) by a gift with reservation (IHTM04071) will depend on how the gift is being taxed. If it is being taxed as part of the deceased’s estate on death, the property transferred will be valued as part of the deceased’s estate. (IHTM04044)

If it is being taxed as a potentially exempt transfer (IHTM04057) the property transferred will be valued on the basis of the loss to the transferor’s estate. (IHTM04054)