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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: gifts with reservation (GWRs): the reservation: annual exemption not available

Where a reservation ceases, the operation is a deemed PET (IHTM04057) under FA86/S102 (4). The deemed PET is chargeable if the donor dies within seven years. The value of that chargeable transfer cannot however be reduced by annual exemption (IHTM14141) in view of the provisions of IHTA84/S19 (5).

Provisions of IHTA84/S19 (5)

This provision disapplies IHTA84/S3(4), which says that all references in the Act to transfers of value include “deemed” transfers of value, except as otherwise provided for. IHTA84/S19 (5) is one such provision, applying in the case of the annual exemption.