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HMRC internal manual

Inheritance Tax Manual

How many variations can be attempted?: special power of appointment, power of enlargement or advancement

In our view the exercise of a special power of appointment, or of a power to enlarge a life interest into an absolute interest, or of a power of advancement is not a variation for the purposes of IHTA84/S142.  Accordingly any subsequent redirection by the beneficiary may qualify as an IHTA84/S142 variation.  If the taxpayer presses the opposite view strongly, or in any case of difficulty, you should refer the case to Technical.