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HMRC internal manual

Inheritance Tax Manual

Introduction to settled property: the trustees

Settled property is held in the name of trustees who are primarily liable for the Inheritance tax (IHTM30091) on the property, but they do not own the property beneficially (IHTM04031). They hold it on trust for the beneficiaries who are the persons entitled to the use and enjoyment of the property, subject to the terms of the trust.

Where there are no trustees of a settlement, IHTA84/S45 provides that the ‘trustee’ for IHT purposes means any person in whom the settled property or its management is for the time being vested.