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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 IoV which purports to redirect to a qualifying charity a bequest to a non-qualifying body. 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 To  
Joint Israel Appeal Jewish Philanthropic Association for Israel and the Middle East  
First Church of Christ Scientist Boston Massachusetts The Christian Science Trust in Great Britain  

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

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 TG.