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HMRC internal manual

Inheritance Tax Manual

Employee benefit trusts: conditions for relief: power to alter trusts

It does not matter if the trustees, or some other person, has the power to alter the trusts, so that persons outside the specified classes in IHTA84/S86(1) could benefit. Nor does it matter if the existing trusts provide that other persons may benefit in the future. You must consider the trusts that actually apply to the settled property at the time the Inheritance Tax charge is being considered.

If the trusts were altered in a way or if reversionary trusts came into operation which did not satisfy the requirements of IHTA84/S86(1), the relief from relevant property trust charges would no longer apply

Where a trust is altered in such a way that the relief no longer applies the trust becomes a relevant property trust (IHTM42161) unless it falls within one of the categories of other trusts outlined at IHTM16061.