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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
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Ten year anniversary: introduction

All discretionary trusts containing relevant property (IHTM42161)incur a charge every ten years, at the ten year anniversary.

Ten year anniversary (TYA) means

  • the tenth anniversary of the date on which the settlement commenced (IHTM42221), and
  • subsequent anniversaries at ten-yearly intervals.

The charge is under IHTA84/S64 and known as the principal charge. It applies to thechargeable value of the relevant property in the settlement on the day before theTYA. You can deduct business and agricultural reliefs to arrive at the chargeablevalue. (IHTM42165)

Grossing never applies to the value at the TYA.

The following pages tell you how to calculate the tax under IHTA84/S66. The rate maycurrently be anything up to 6%. Apart from the relevant property itself, all othercumulative values are historic (not current) values.