Commentary

I12.713 Commercial trusts

IHT, trusts and estates

I12.713 Commercial trusts

I12.713 Commercial trusts

These normally take the form of employee benefit trusts, although some may fall within the heading of unapproved retirement schemes, now described as employer financed retirement benefit schemes. As the transfer into trust is made by an employer company, there should be no chargeable transfer for inheritance tax purposes, because companies are not within the scope of the tax. Of course, the inheritance tax position is far from being that simple. In the case of a close company, the problems flow from the fact that the participators of the company are treated as making a chargeable transfer

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