If the gift was after 9 March 1999 s102 FA 1986 cannot apply, and the position is governed by either s102A or s102B.
S 102B is for gifts of share in land and there is no reservation of benefit under that section if the land concerned is let.
S102A is for other kinds of division of rights over land (reversionary leases for example), and it is arguable that equally it does not apply if the land is let. The notes in the annotated Finance Act 1999 suggested this to be so. It refers to a enjoying a right in relation to all or part of the land, which seems apt to describe rights over the land, rather than the rent produced by letting the land. There seems no reason why let land should be excluded from the scope of s102B but not s102A.
M B Gunn & Co Ltd.