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HMRC internal manual

Inheritance Tax Manual

Property at more than one title: lifetime cumulative total and gifts with reservation

Where there are different funds (IHTM26211) and chargeable lifetime transfers (IHTM14000) which cumulate (IHTM14501) with the death estate, the lifetime transfers are a component of the rate for grossing (IHTM26121) purposes for each fund.

You can find examples of this at IHTM26143, IHTM26144 and IHTM26158.

A gift with reservation (GWR) (IHTM14025) (where it is charged as part of the death estate (IHTM14301)) and the free estate are two different funds. But, where a GWR was made within the cumulative period it may instead be charged as a potentially exempt transfer (PET) (IHTM14024), under the double charges rules (IHTM14711).

If the transfer is a PET under those rules there will be an impact on the grossing calculations which will not arise if it is treated as a GWR.