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HMRC internal manual

Inheritance Tax Manual

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

In the case of Von Ernst and Cie S.A. v IRC [1980] 1 WLR 468 the Court ruled that any payment or potential payment from the settled property to an incorporated UK charity - to be used by the charity for its charitable purposes - would not be an application for the ‘benefit’ of the charity. So, you should not deny the exclusion for exempt securities just because a qualifying charity (whether incorporated or not) has received or might receive any of the settled property or income from it.