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HMRC internal manual

Inheritance Tax Manual

Property redirected to a charity: redirection to a charity by a non-qualifying body

The taxpayers may seek charity exemption as a result of an instrument of variation IoV) which purports to redirect a bequest to a non-qualifying body to a qualifying charity.  If the original non-qualifying beneficiary, whether UK or foreign, has effectively and completely divested itself of any benefit, for example, in the case of a collecting agency making a variation in favour of an independent charity, this may be acceptable providing the requirements of IHTA84/S142 are fully met.  In particular, instruments which redirect a benefit from the organisations below to the recipients shown are acceptable if the necessary conditions are met

  • From the Joint Israel Appeal to Jewish Philanthropic Association for Israel and the Middle East
  • From the First Church of Christ Scientist Boston Massachusetts to the Christian Science Trust in Great Britain

IoVs involving other organisations in these circumstances should be referred to Risk.

Where the information suggests that the new body is no more than a conduit by which the benefit will filter back to the original beneficiary, the matter should be referred to Technical.