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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Foreign property: discretionary trusts and exempt securities: introduction

Under IHTA84/S48 (4)(b) exempt securities will be excluded from the IHT charge on a transfer if they are settled property held on discretionary trusts (where no qualifying interest in possession subsists in them), immediately before a transfer, and:.

  • all ‘known persons’ (IHTM27248) for whose benefit any of the settled property (or income from it) has been, or might be, applied satisfy the conditions specified by the securities (IHTM27241).

The same conditions must also be satisfied for any person who is, or might become, entitled to a qualifying interest in possession in any of the settled property.