IHTM25381 | Gifts with reservation: Introduction
From HM Revenue & Customs · Inheritance Tax Manual
Assets charged under the gift with reservation (GWR) rules have to satisfy two conditions to qualify for business relief
at the time of the gift the asset given has to be relevant business property (), and
at the time of the GWR charge (on the death of the donor or earlier release of the reservation) the asset would qualify for business relief if the donee then made a notional transfer of value () of it.