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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: associated operations: gifts with reservation (GWRs)

Where there is a disposal by way of gift, and the donor obtains a benefit through associated operations, treat this as a benefit to the donor ‘by contract or otherwise’ for the purposes of FA86/S102.

This is covered in more depth at the GWR (IHTM14338) section of this manual.