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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Special valuation matters: occupation of settled property amounting to a lease for life

The circumstances in which occupation might amount to a lease for life are considered in detail in the section on settled property (IHTM16191). However, there can be no question of such a subsidiary settlement if

  * the lease is at a rack rent, or
  * terminable at any time at the will of the trustees

Any cases where a reference to the VOA ([IHTM23002]( is required should be referred to TG (IHTM01080) in the first instance.