Commentary

I5.532 Transfers out of an A&M trust

IHT, trusts and estates

I5.532 Transfers out of an A&M trust

I5.532 Transfers out of an A&M trust

Property within an accumulation and maintenance (A&M) trust is not relevant property and as such there are no periodic charges (I5.304)1 or exit charges (I5.305, I5.307)2 on the property.

Instead when property leaves an A&M trust there is a charge to tax3 which is calculated on the same basis as those described in I5.643, I5.6444 (the exit charge on property leaving favoured trusts), except that the relevant period (I5.644) in relation to which the tax rate is calculated is the period beginning with the later of:

  1.  

    •     the day on which the settled property in respect of which tax is chargeable became (or last became) property to which the A&M trust regime applies, and

  2.  

    •     13 March 1975

and ending with the day before the event giving rise to the charge5.

Exceptions from the charge

The most common exception is where, on 6

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