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HMRC internal manual

Inheritance Tax Manual

Reduced rate for gifts to charity: components of the estate: reservation of benefit property

Property in which a reservation of benefit subsists (IHTM04071) is not included as a component of the estate as such property cannot by itself qualify for the reduced rate.

This is because the reservation of benefit rules do not apply to gifts to charity, FA86/S102(5)(d).

However, such property may be eligible for the reduced rate if an election (IHTM45035) to merge it with, say, the general component is made, IHTA84/Sch1A/Para 7(5)(b) .