A charge will not arise under FA 1986, s. 102 (either on the donor's death or on release of the reservation), to the extent that the disposal subject to reservation is an exempt transfer by virtue of being any of the following (FA 1986, s. 102(5)):

transfer between spouses or civil partners (except as provided by FA 1986, s. 102(5A) and (5B) – see below);

small gift;

marriage or civil partnership gift;

gift to charity;

gift to political party;

gift (on or after 14 March 1989) to housing association);

gift for national purposes, etc.;

gift to public benefit;

gift to maintenance fund for historic buildings;

Want to read more?

This content requires a Croner-i Tax and Accounting subscription.

No subscription?

Contact us to discuss your requirements.