Commentary

I5.209 Commercial transactions deemed as QIIP

IHT, trusts and estates

I5.209 Commercial transactions deemed as QIIP

I5.209 Commercial transactions deemed as QIIP

This category of a qualifying interest in possession (QIIP) was included as an anti-avoidance measure by FA 2010, s 53.

It ensures that the IHT regime for QIIPs applies to an interest in possession to which a person (domiciled in the UK) became beneficially entitled on or after 9 December 2009 which is within IHTA 1984, s 10 (commercial transactions; see I3.141).

Such property forms part of the estate of the person entitled to it1, so that it is subject to the IHT charge on death, and the termination of such an interest during

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