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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Liability in special cases: discretionary trust charges and heritage property

Where heritage property (IHTM04110) is comprised in a settlement and has been exempted from the ten yearly charge, the persons liable for the tapered charge which may arise under IHTA84/S79 (3) are specified in IHTA84/S207 (3). They are

  • the trustees of the settlement, and
  • any person for whose benefit any of the property or income from it is applied at or after the time of the event occasioning the charge.