Policy paper

Statement of Practice E5

Published 1 April 1978

The Commissioners for HM Revenue and Customs consider that the general intention of Inheritance Tax Act (IHTA) 1984 section 101 is to treat the participators as beneficial owners for all the purposes of that Act. Consequently, the conditions of IHTA 1984 sections 52(2), 53(2) are regarded as satisfied where it is the company that in fact becomes entitled to the property or disposes of the interest.