IHTM45006 | Reduced rate for gifts to charity: components of the estate: reservation of benefit property
From HM Revenue & Customs · Inheritance Tax Manual
Property in which a reservation of benefit subsists () is not included as a component of the estate as such property cannot by itself qualify for the reduced rate.
This is because the reservation of benefit rules do not apply to gifts to charity, .
However, such property may be eligible for the reduced rate if an election () to merge it with, say, the general component is made, IHTA84/Sch1A/Para 7(5)(b) .