Commentary

I5.555 Tax implications—depreciatory transactions within an 18–25 trust

IHT, trusts and estates

I5.555 Tax implications—depreciatory transactions within an 18–25 trust

I5.555 Tax implications—depreciatory transactions within an 18–25 trust

Where the 18–25 trust rules do not cease to apply to settled property, but the trustees make a disposition as a result of which the value of settled property to which the section applies is less than it would be but for the disposition, there is a charge to IHT on the diminution in value of the property1. Disposition includes an omission to exercise a right (unless shown not to be deliberate)2, and, where the trustees are participators in a close company and the shares are property to which the 18–25 trust

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