Commentary

I5.1107 An 'arrangement' as a settlement

IHT, trusts and estates

I5.1107 An 'arrangement' as a settlement

I5.1107 An 'arrangement' as a settlement

The definition of a settlement for the purposes of these provisions is in very wide terms (see I5.1105). There is usually little difficulty in establishing the existence of a settlement where there are documents setting up a trust, but where there is no formal trust there are diverging views on whether in a particular case the 'arrangements' amount to a settlement1.

In the Tax Bulletin 64 (April 2003), HMRC provided information and examples on the settlements legislation2 which concentrated on its application to businesses and individuals. The article was the subject of considerable criticism by

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