Commentary

I5.256 QIIPs and trustees' annuities

IHT, trusts and estates

I5.256 QIIPs and trustees' annuities

I5.256 QIIPs and trustees' annuities

IHT is not charged on the coming to an end of a trustee's annuity of the type considered in I5.214 even if it is a qualifying interest in possession, except to the extent that it represents more than reasonable remuneration1.This would also apply on a coming to an end of the annuity both during the life and on the death, of a trustee annuitant.

Where one trustee's annuity terminates and there is a gap between that event and the arising of an annuity for another trustee, HMRC will probably regard this exemption as applying to negate

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