IHTM14343 - 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). »Ê¹ÚÌåÓýapp deemed PET is chargeable if the donor dies within seven years. »Ê¹ÚÌåÓýapp 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.