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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Employee benefit trusts: conditions for relief: charities

Under IHTA84/S86(2) trusts which permit property to be applied for the benefit of persons within IHTA84/S86(1)(a) or (b) do not lose the relief if they also permit the property to be applied for charitable purpose. Funds set up with the firm intention of benefiting the employees often provide that when the trust is wound up the trust capital will be paid to specified individuals or to a charity.

Also see IHTM42933 regarding insolvency.