The following Private Client Q&A provides comprehensive and up to date legal information covering:
In answering this Q&A we have assumed the following:
that the trust and the company in question are both resident outside the UK for UK tax purposes
that the trust’s shareholding in the company constitutes an interest in a close company within the meaning of paragraph 2(1) of Part 1 of Schedule A1 of the Inheritance Tax Act 1984 (IHTA 1984)
that the residential property in question constitutes a UK residential property interest within the meaning of IHTA 1984, Sch A1, Pt 1, para 8
that the trust has made a loan to the company, which is still outstanding
IHTA 1984, Sch A1, Pt 1, para 2(5) states:
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