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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Investigating Event Form: IHT 100c - Assets in a discretionary trust ceasing to be relevant property (proportionate charge)

This is a dual purpose form to inform this office about:

  • assets ceasing to be relevant property IHTA84/S58 in a relevant property trust that give rise to a proportionate charge before the first ten year anniversary IHTA84/S68, or
  • assets distributed after the first ten year anniversary IHTA84/S69.

You would have to consider the following in relation to the information provided:

Section 1

  • Has the discretionary trust come to an end
  • Does grossing up (IHTM14593) apply

Section 2

  • Have there been any additional assets since the settlement commenced
  • Has there been any additional relevant property since the settlement commenced, if so are there any valuation requirements i.e. realty, shares.

Section 3

  • Have there been any amendments since the last ten year anniversary, if so what.
  • Have there been any assets within the settlement, which has now become relevant property.

Section 4

  • Double taxation relief (IHTM27181) details.