Commentary

I11.111 The position of the Crown

IHT, trusts and estates

I11.111 The position of the Crown

I11.111 The position of the Crown

The Crown is recognised to be immune from tax unless bound by express words1. In addition it is expressly provided that a gift to any government department, including the National Debt Commissioners is, subject to certain conditions2, an exempt transfer for IHT purposes.

Where property passes to the Crown it will not be possible for HMRC to sue the Crown for any IHT due. For this purpose the Crown includes many3 but not all4 government agencies and servants and agents of the executive government. This cannot affect the liability of the transferor.

As regards relations between

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