IHTM14338 | Lifetime transfers: gifts with reservation (GWRs): the reservation: benefit by associated operations

From HM Revenue & Customs · Inheritance Tax Manual

Treat a benefit which a donor obtains through associated operations () as a benefit to him ‘by contract or otherwise’ ().

Where a person gives away property with a reservation to their spouse or civil partner (), that will not in itself be a gift with reservation (GWR). However, if they share the spouse’s or civil partner’s enjoyment or benefit, it may be said that the donor has not been entirely excluded.