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).