Commentary

I5.340 Survivorship clauses and exit charges

IHT, trusts and estates

I5.340 Survivorship clauses and exit charges

I5.340 Survivorship clauses and exit charges

Where a Will or other disposition contains a survivorship clause of no more than six months' duration, the dispositions taking effect at the end of the survivorship period (or on the death, if earlier, of the intended beneficiary) are treated1 (see I4.453) as if they had taken place at the beginning of the survivorship period.

The effect of this will only be one of eliminating a tax charge if there would otherwise have been an IHT charge at the beginning of the survivorship period (eg on the termination of an interest in possession).

If, for

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