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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
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Lifetime transfers: gifts with reservation (GWRs): the reservation: benefit by associated operations

Treat a benefit which a donor obtains through associated operations (IHTM14822) as a benefit to him ‘by contract or otherwise’ (IHTM14831).

Where a person gives away property with a reservation to their spouse or civil partner (IHTM11032), that will not in itself be a gift with reservation (GWR). However, if they share the spouse’s or civil partner’s enjoyment or benefit, it may be said that the donor has not been entirely excluded.