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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: gifts with reservation (GWRs): the gift: interest free loans

The grant of an interest free loan repayable on demand

  • is not a transfer of value (because the value of the right to repayment of the loan is equal to the amount of it)
  • but it is a gift because there is a clear intention to confer bounty: the property disposed of is the interest foregone.

But, the grant of such a loan is not, in itself, a GWR.

There is however a special provision relating to loans to settlements which is mentioned later in this section (IHTM14401).