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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
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Foreign property: discretionary trusts and exempt securities: exit charge

At IHTA84/S65, the rules relating to discretionary trusts provide for a tax charge when property ceases to be relevant property (leaves the discretionary trust regime). Where property in a discretionary trust becomes excluded property (and therefore ceases to be relevant property) for the sole reason that it is invested in exempt securities, the usual exit charge does not apply if the settlor’s domicile (under general law) was outside the UK at the time the settlement was made.

IHTA84/S65(7A) inserted by FA13/S175 provides for the same treatment to apply to investment in AUTs or OEICs (IHTM04262).