Statement of Practice E7
Published 1 April 1978
© Crown copyright 1978
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In the Commissioners for HM Revenue and Customs (HMRC) view, the reference to trusts ‘to the like effect as those specified in section 33(1) of the Trustee Act 1925’ - contained in Inheritance Tax Act 1984 sections 73 and 88 - is a reference to trusts which are not materially different in their tax consequences.
The Commissioners for HMRC would not wish to distinguish a trust by reason of a minor variation or additional administrative duties or powers. The extension of the list of potential beneficiaries to, for example, brothers and sisters is not regarded as a minor variation.