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HMRC internal manual

Inheritance Tax Manual

Life Policies: Married Women’s Property Act policies: trustee’s remuneration

If a policy of insurance that creates a trust (under the operation of the Married Women’s Property Act or otherwise) contains a clause authorising a professional trustee to charge for their services you should not use this as an argument that the trust is not valid.

In such a case tax, where chargeable, should be claimed on the gross amount to which the claim would extend in the absence of the charging clause, no allowance being made in the first instance for the trustee’s remuneration.

You should refer any case in which this is challenged to Technical.