Commentary

70 Inheritance tax: relevant property trusts

POWERS OF APPOINTMENT vol 33
| Commentary

70 Inheritance tax: relevant property trusts

| Commentary

70 Inheritance tax: relevant property trusts

Appointments out of ‘relevant property’1, that is, property in which there is no qualifying interest in possession2, will normally give rise to an exit charge3 if the appointed property ceases to be relevant property. This is the case if property held in a discretionary trust is appointed to a beneficiary absolutely.

The amount on which tax is charged is the amount by which the value of the relevant property in the settlement is reduced by the property appointed4, although this sum is grossed up if the tax

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