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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 GWR (IHTM04071) will depend on how the gift is being taxed. If it isbeing taxed as part of the deceased’s estate on death, the property transferred willbe valued as part of the deceased’s estate. (IHTM04044)If it is being taxed as a PET, (IHTM04057) the propertytransferred will be valued on the basis of the loss to the transferor’s estate. (IHTM04054)