Commentary

I6.132 Apportionment to trustee participators

IHT, trusts and estates

I6.132 Apportionment to trustee participators

I6.132 Apportionment to trustee participators

Where any part of the value transferred by a close company is apportioned to the trustees of a settlement, the effect of that apportionment depends upon whether or not a qualifying interest in possession (QIIP)1 subsists in the settled property — see I5.201 for further information on QIIPs2.

If a QIIP does subsist, part of the interest is treated as having come to an end on the making of the transfer3. There is then a deemed transfer of value under IHTA 1984, s 52 (see I5.221–I5.223 and, I5.229). If there is no such interest in possession,

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