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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
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The settlor: settlement made before 11 December 1974

Under IHTA84/S201 (3) the settlor is not liable under IHTA84/S201 (1)(d) in relation to a settlement made before 11 December 1974 if

  • the trustees were resident in the United Kingdom when the settlement was made and
  • the trustees have not been resident in the United Kingdom at any time between 10 December 1974 and the time of the transfer.