IHTM14343 - The reservation: annual exemption

Where a reservation ceases, the operation is a deemed PET ( IHTM04057) under FA86/S102 (4). The deemed PET is chargeable if the donor dies within seven years.

• The value of that chargeable transfer cannot however be reduced by annual exemption ( IHTM14141).

Provisions of IHTA84/S19 (5)

This provision disapplies IHTA84/3 (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.